Joint Industry Plan; Order Approving an Amendment to the National Market System Plan Governing the Consolidated Audit Trail, as Modified by the Commission, To Further Reduce the Costs of the Consolidated Audit Trail

Federal RegisterApr 1, 2026

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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-105107; File No. 4-698]

Joint Industry Plan; Order Approving an Amendment to the National Market System Plan Governing the Consolidated Audit Trail, as Modified by the Commission, To Further Reduce the Costs of the Consolidated Audit Trail

March 27, 2026.

I. Introduction

On December 17, 2025, the Consolidated Audit Trail, LLC (“CAT LLC”), on behalf of the Participants

to the National Market System Plan Governing the Consolidated Audit Trail (“CAT NMS Plan” or “Plan”),

filed with the Securities and Exchange Commission (“Commission”), pursuant to Section 11A of the Exchange Act

and Rule 608 of Regulation National Market System (“Regulation NMS”) thereunder,

a proposed amendment to the CAT NMS Plan to implement various cost savings measures (the “Initial Proposed Amendment”) for the consolidated audit trail (“CAT”).

The Initial Proposed Amendment was published for comment in the

Federal Register

on December 31, 2025.

On February 24, 2026, CAT LLC, on behalf of the Participants of the CAT NMS Plan, filed an amendment to the Initial Proposed Amendment.

The Participants are: 24X National Exchange LLC, BOX Exchange LLC, Cboe BYX Exchange, Inc., Cboe BZX Exchange, Inc., Cboe C2 Exchange, Inc., Cboe EDGA Exchange, Inc., Cboe EDGX Exchange, Inc., Cboe Exchange, Inc., Financial Industry Regulatory Authority, Inc. (“FINRA”), Investors Exchange LLC, Long-Term Stock Exchange, Inc., MEMX LLC, Miami International Securities Exchange LLC, MIAX Emerald, LLC, MIAX PEARL, LLC, MIAX Sapphire, LLC, Nasdaq GEMX, LLC, Nasdaq ISE, LLC, Nasdaq MRX, LLC, Nasdaq PHLX LLC, Nasdaq Texas, LLC, The NASDAQ Stock Market LLC, New York Stock Exchange LLC, NYSE American LLC, NYSE Arca, Inc., NYSE National, Inc., and NYSE Texas, Inc. (collectively, the “Participants,” “self-regulatory organizations,” or “SROs”).

The CAT NMS Plan is a national market system plan approved by the Commission pursuant to Section 11A of the Securities Exchange Act of 1934 (“Exchange Act”) and the rules and regulations thereunder.

See

Securities Exchange Act Release No. 78318 (Nov. 15, 2016), 81 FR 84696 (Nov. 23, 2016) (“CAT NMS Plan Approval Order”). The CAT NMS Plan is Exhibit A to the CAT NMS Plan Approval Order.

See

CAT NMS Plan Approval Order, 81 FR at 84943-85034. The CAT NMS Plan functions as the limited liability company agreement of the jointly owned limited liability company formed under Delaware state law through which the Participants conduct the activities of the CAT (“Company”). Each Participant is a member of the Company and jointly owns the Company on an equal basis. The Participants submitted to the Commission a proposed amendment to the CAT NMS Plan on August 29, 2019, which they designated as effective on filing. On August 29, 2019, the Participants replaced the CAT NMS Plan in its entirety with the limited liability company agreement of a new limited liability company, CAT LLC, which became the Company.

See

Securities Exchange Act Release No. 87149 (Sept. 27, 2019), 84 FR 52905 (Oct. 3, 2019). The latest version of the CAT NMS Plan is available at

https://catnmsplan.com/about-cat/cat-nms-plan.

15 U.S.C. 78k-1.

17 CFR 242.608.

See

Letter to Vanessa Countryman, Secretary, Commission, from Robert Walley, Chair, CAT NMS Plan Operating Committee, dated Dec. 17, 2025.

See

Securities Exchange Act Release No. 104504 (Dec. 23, 2025), 90 FR 61506 (“Notice”). Comments received in response to the Notice can be found on the Commission's website at

https://www.sec.gov/rules-regulations/public-comments/4-698.

See

Letter to Vanessa Countryman, Secretary, Commission, from Robert Walley, Chair, CAT NMS Plan Operating Committee, dated Feb. 24, 2026,

available at:

https://www.sec.gov/comments/4-698/4698-715067-2238014.pdf

(“CAT LLC February 2026 Letter”). In the CAT LLC February 2026 Letter, CAT LLC proposes to update the Initial Proposed Amendment to reflect the intervening changes to the language of the CAT NMS Plan following the Commission's approval of the CAIS Amendment,

infra

note 20, on January 13, 2026.

See

CAT LLC February 2026 Letter, at 1.

This order approves the Proposed Amendment, as modified by the Commission (hereinafter, the “Proposed Amendment” unless otherwise noted). For the reasons discussed below, the Commission finds that the Proposed Amendment, as modified by the Commission, is appropriate in the public interest, for the protection of investors and the maintenance of fair and orderly markets, to remove impediments to, and perfect the mechanism of, a national market system, or is otherwise in furtherance of the purposes of the Exchange Act.

II. Background

On July 11, 2012, the Commission adopted Rule 613 of Regulation NMS, which required the SROs to submit a national market system (“NMS”) plan to create, implement and maintain a consolidated audit trail that would capture customer and order event information for orders in NMS securities.

The goal of Rule 613 was to create a modernized audit trail system that would provide regulators with timely access to a comprehensive set of trading data, thus enabling regulators to more efficiently and effectively analyze and reconstruct market events, monitor market behavior, conduct market analysis to support regulatory decisions, and perform surveillance, investigation, and enforcement activities.

On November 15, 2016, the Commission approved the CAT NMS Plan.

17 CFR 242.613.

See

Securities Exchange Act Release No. 67457 (July 18, 2012), 77 FR 45722, 45730-33 (Aug. 1, 2012).

See

CAT NMS Plan Approval Order.

In the CAT NMS Plan Approval Order issued in 2016, the Commission estimated that the ongoing annual costs associated with maintaining and operating the Central Repository

would be approximately $55.8 million.

But CAT operating costs have far exceeded these estimates

due largely to increases in trading activity, which impacts various CAT cost drivers like storage, data processing, and message traffic.

Pursuant to the CAT NMS Plan, the CAT must process and store extremely large and increasing data volumes, resulting in millions of dollars of ongoing costs. Recently, the Commission has issued orders either approving amendments designed in whole or in part to reduce the operating costs of the CAT, or providing exemptive relief designed to reduce these costs, as discussed below.

“Central Repository” means “the repository responsible for the receipt, consolidation, and retention of all information reported to the CAT pursuant to SEC Rule 613 and [the CAT NMS Plan].”

See

CAT NMS Plan, at Section 1.1.

See, e.g.,

CAT NMS Plan Approval Order, at 84918-20.

The CAT budget initially approved by the Participants for 2025 was approximately $249 million.

See

Notice, at 61506; Consolidated Audit Trail, LLC 2025 Financial and Operating Budget (Nov. 11, 2024)

https://catnmsplan.com/sites/default/files/2024-11/11.20.24-CAT-LLC-2025-Financial_and_Operating-Budget.pdf.

See, e.g.,

Securities Exchange Act Release No. 98290 (Sept. 6, 2023), 88 FR 62628, 62641 (Sept. 12, 2023).

CAT LLC states that it and the Plan Processor have continuously pursued cost savings measures within their control and have achieved meaningful cost reductions within the significant regulatory restraints of the CAT NMS Plan.

See

Notice, at 61506. For example, CAT LLC states that as a result of the optimizations pursued by CAT LLC and the Plan Processor, per unit costs have decreased significantly, allowing cloud fees to remain generally flat over the last three years despite 41% growth in data volumes over the same three-year period—$136 million and 109 trillion events in 2022, $128 million and 116 trillion events in 2023, and $135 million and 154 trillion events in 2024.

Id.

at 61506 n.7. CAT LLC states that more comprehensive cost reductions require Commission approval to permit their implementation.

See id.

at 61506.

On December 12, 2024, the Commission approved a CAT NMS Plan Amendment that, among other things, permitted more efficient processing and storage of Options Market Maker Quotes in Listed Options, allowed for more cost-effective storage of raw, interim, submission and feedback files older than 15 days, and codified and expanded upon exemptive relief that permitted the deletion of industry test data older than 3 months (“2024 Cost Savings Amendment”).

CAT LLC states that the 2024 Cost Savings Amendment was originally estimated to

result in roughly $20 million in additional annual savings in the first year, but actual savings have proven better than anticipated and are now projected to be approximately $30 million in the first year.

See

Securities Exchange Act Release No. 101901 (Dec. 12, 2024), 89 FR 103033 (Dec. 18, 2024).

In May 2025, the Participants revised the budget down by $21 million dollars to approximately $228 million to reflect cost savings achieved through the implementation of the 2024 Cost Savings Amendment and other optimizations.

See

Notice, at 61506; Consolidated Audit Trail, LLC 2025 Financial and Operating Budget (May 19, 2024),

https://www.catnmsplan.com/sites/default/files/2025-05/05.19.25-CAT-LLC-2025-Financial_and_Operating-Budget.pdf.

In November 2025, the Participants further revised the budget down by another $40 million to approximately $188 million due to further implementation of the 2024 Cost Savings Amendment and other optimizations.

See

Notice, at 61506; Consolidated Audit Trail, LLC 2025 Financial and Operating Budget (Nov. 7, 2025),

https://www.catnmsplan.com/sites/default/files/2025-11/11.07.25-CAT-LLC-2025-Finacial_and_Operating-Budget.pdf.

This $188 million budget includes approximately $122 million in cloud hosting fees, $54 million in Plan Processor operating fees and expenses, and other general and administrative costs.

See

Notice, at 61506.

On September 30, 2025, the Commission issued an exemptive relief order designed to allow the Participants to reduce the operating costs of CAT (“2025 Cost Savings Exemptive Order”).

Among other things, the 2025 Cost Savings Exemptive Order granted exemptive relief with respect to four areas: (A) requirements to create lifecycle linkages by T+1 (transaction date + one day) at noon Eastern Time; (B) requirements for reprocessing of late records; (C) requirements to provide an online targeted query tool (“OTQT”); and (D) requirements related to data storage and retention.

See

Securities Exchange Act Release No. 104144 (Sept. 30, 2025), 90 FR 47853 (Oct. 2, 2025).

Id.

at 47854. CAT LLC states that the most recent 2025 budget does not reflect the potential cost savings related to the 2025 Cost Savings Exemptive Order and that any such cost savings would be reflected in 2026 or subsequent years after technology and other changes related to the 2025 Cost Savings Exemptive Order are implemented.

See

Notice, at 61506 n.11.

And most recently, the Commission approved a proposed amendment, with modifications, that would, among other things, eliminate all CAT NMS Plan requirements to report customer names, addresses, and dates of birth information for all customers, and require the deletion of previously reported Customer names, addresses, and dates of birth information from the CAIS, and achieve an estimated $7 to $9 million in annual cost savings (the “CAIS Amendment”).

See

Securities Exchange Act Release No. 104586 (Jan. 13, 2026), 91 FR 2164 (Jan. 16, 2026) (“CAIS Amendment Approval Order”).

As discussed in the Notice, CAT LLC states that it developed a proposal, which was not submitted to the Commission (the “Original CAT LLC Proposal”), designed to maximize cost savings while preserving the CAT's core regulatory functionality, and which was estimated to provide approximately $70 to $90 million in annual cost savings, including an annual reduction in cloud hosting fees of $55 to $75 million, and approximately $15 million in total Plan Processor operating fees.

CAT LLC states that the Original CAT LLC Proposal was not submitted as a proposed amendment because the “clear consensus” of discussions with members of the Advisory Committee, the Securities Industry and Financial Markets Association (“SIFMA”) and the Financial Information Forum (“FIF”) was that certain aspects of the Original CAT LLC Proposal would impose certain compliance costs on Industry Members.

See

Notice, at 61507. CAT LLC states that the Plan Processor's estimates of Plan Processor operating fees for the Original CAT LLC Proposal and the modified proposal as set forth in this 2025 Cost Savings Amendment are preliminary and directional and are subject to change based on the final, SEC-approved requirements and execution of a new definitive agreement between CAT LLC and Plan Processor.

See id.

at 61506 n.13. CAT LLC states that these estimates are annualized for 2026 based on the estimated Plan Processor operating fees for the reduced scope of work reflected in the Original CAT LLC Proposal and the Modified Proposal, as applicable.

Id.

CAT LLC states that the “contract year” for the Plan Processor Agreement with FINRA CAT is offset from the calendar year, and so the actual total Plan Processor operating fees for calendar year 2026 will vary from these annualized estimates, and that the Plan Processor operating fees for future years will also be subject to adjustments as agreed between CAT LLC and FINRA CAT (

e.g.,

change orders, market data providers and inflation adjustments based on a cost of labor index).

Id.

See id.

at 61508.

CAT LLC then submitted the Proposed Amendment, which would provide an estimated cost savings of $55 million to $73 million and would consist of seven items: (i) Interim CAT Order-ID Amendment; (ii) Data Storage Amendment; (iii) Late Data Re-Processing Amendment; (iv) OTQT Amendment; (v) Rejected Message Amendment; (vi) Data Availability Amendment; and (vii) Reference Data Amendment.

Some of these items are in whole or in part consistent with the 2025 Cost Savings Exemptive Order, and approval of them would in whole or in part codify previously granted exemptive relief.

In the Proposed Amendment CAT LLC also provided additional detail and requested comment on two components of the Original CAT LLC Proposal, specifically the “Full Elimination of CAIS/CCID Component,” and “Reduced Linkage Processing Timeline Component.”

All of these items are discussed in greater detail below.

See id.

at 61508-09. The Proposed Amendment also provide for a “spending cap” provision,

see infra

Part III.H.

See, e.g.,

id.

at 61510 (stating that the Interim CAT-Order-ID Amendment is “consistent with and would codify the exemptive relief related to interim CAT-Order-ID as set forth” in the 2025 Cost Savings Exemptive Order); 61521 (stating that the OTQT Amendment “is consistent with and would codify the exemptive relief related to the OTQT as set forth” in the 2025 Cost Savings Exemptive Order).

See id.

at 61509.

CAT LLC states that all cost and savings projections described in the Proposed Amendment are estimates only and reflect the current CAT operations.

CAT LLC states that cost savings estimates are based on, among other factors: current CAT NMS Plan requirements; reporting by Participants, Industry Members and market data providers; observed data rates and volumes; current discounts, reservations and cost savings plans and associated cloud fees.

CAT LLC states that actual future savings could be more or less than estimated due to changes in any of these variables.

In addition, CAT LLC states that savings projections are primarily based on production environments, which represent approximately two-thirds of all cloud fees.

CAT LLC states that the cost savings under the 2025 Cost Savings Amendment will be meaningful, even if the magnitude of the estimated savings cannot be determined with absolute certainty, and that the estimates and assumptions they described provide an adequate basis for the Commission to evaluate the costs and benefits of the proposed amendment.

CAT LLC further notes that the estimated cost savings do not reflect or incorporate potential cost savings related to the 2025 Cost Savings Exemptive Order.

CAT LLC also notes that, in some cases as noted below, the potential cost savings allowed under the 2025 Cost Savings Exemptive Order and the cost savings described in this 2025 Cost Savings Amendment may differ.

See id.

at 61507-08 n.12.

See id.

III. Discussion and Commission Findings

After careful review, the Commission, pursuant to Section 11A of the Exchange Act,

and Rule 608(b)(2)

thereunder, is approving the Proposed Amendment with certain modifications from the Commission. Section 11A of the Exchange Act authorizes the

Commission, by rule or order, to authorize or require the self-regulatory organizations to act jointly with respect to matters as to which they share authority under the Exchange Act in planning, developing, operating, or regulating a facility of the national market system.

Rule 608 of Regulation NMS authorizes two or more SROs, acting jointly, to file with the Commission proposed amendments to an effective NMS plan,

and further provides that the Commission shall approve an amendment to an effective NMS plan if it finds that the amendment is necessary or appropriate in the public interest, for the protection of investors and the maintenance of fair and orderly markets, to remove impediments to, and perfect the mechanisms of, a national market system, or otherwise in furtherance of the purposes of the Exchange Act.

15 U.S.C. 78k-1.

17 CFR 242.608(b)(2).

See

15 U.S.C. 78k-1(a)(3)(B).

See

17 CFR 242.608.

See

17 CFR 242.608(b)(2).

The Participants have sufficiently demonstrated that the proposed cost savings measures, as modified by the Commission, are appropriate. There are a number of potential approaches to reducing the costs of the CAT, all of which have estimated savings of varying amounts and potential downsides, such as increased costs for Industry Members or a reduction in the regulatory utility of the CAT. As modified, the Proposed Amendment strikes a reasonable and appropriate balance between reducing costs and preserving the core regulatory functionality and utility of the CAT. Furthermore, approval of the Proposed Amendment does not foreclose the implementation of further measures designed to reduce the costs of the CAT, and as part of the ongoing comprehensive review of the CAT,

the Commission expects to engage with the Participants, Industry Members, and the public more broadly on issues relating to the costs of the CAT and potential cost savings measures, among other things.

See

Securities Exchange Act Release No. 104144 (Sept. 30, 2025), 90 FR 47853, 47854 (Oct. 2, 2025) (stating that “the Chairman of the Commission instructed the staff to undertake a comprehensive review of the CAT” and citing Prepared Remarks Before SEC Speaks, Chairman Paul S. Atkins, May 19, 2025,

available at

https://www.sec.gov/newsroom/speeches-statements/atkins-prepared-remarks-sec-speaks-051925

See also

Notice, at 61509 (calling for comments and quantitative data from Industry Members regarding, among other things, whether Industry Members support the continued existence of the CCID (under the Reference Data Amendment,

see infra

Part III.G, or otherwise) or would support its full elimination, and the costs and benefits that could result from either approach.

A. Interim CAT-Order-ID Amendment

The Interim CAT-Order-ID Amendment proposes to amend the CAT NMS Plan to eliminate the daily delivery of an interim CAT-Order-ID and instead provide for delivery of interim CAT-Order-IDs only on an “as requested by the SEC” basis.

CAT LLC states that the Interim CAT-Order-ID Amendment is consistent with and would codify the exemptive relief relating to interim lifecycle requirements granted in the 2025 Cost Savings Exemptive Relief Order.

See

Notice, at 61510-12.

See

id. at 61510; 2025 Cost Savings Exemptive Relief Order, at 47854-56.

Appendix D, Section 6.1 of the CAT NMS Plan states that “Noon Eastern Time T+1 (transaction date + one day)” is the deadline for “[i]nitial data validation, lifecycle linkages and communication of errors to CAT Reporters.”

The CAT NMS Plan further states that the Plan Processor

must “link and create the order lifecycle” using a “daisy chain approach,” in which “a series of unique order identifiers, assigned to all order events handled by CAT Reporters[,] are linked together by the Central Repository and assigned a single CAT-generated CAT-Order-ID that is associated with each individual order event and used to create the complete lifecycle of an order.”

The Plan Processor provides the lifecycle linkages that are required on T+1 by assigning an interim CAT-Order-ID.

A final CAT Order ID is then assigned when corrected and linked data is processed and made available to regulators on T+5 at 8 a.m. Eastern Time.

See

CAT NMS Plan, at Appendix D, Section 6.1;

see id.

at Section 1.1 (defining “CAT Reporter” as “each national securities exchange, national securities association and Industry Member that is required to record and report information to the Central Repository pursuant to SEC Rule 613(c)”).

“Plan Processor” is defined as “the Initial Plan Processor or any other Person selected by the Operating Committee pursuant to SEC Rule 613 and Sections 4.3(b)(i) and 6.1, and with regard to the Initial Plan Processor, the Selection Plan, to perform the CAT processing functions required by SEC Rule 613 and set forth in [the CAT NMS Plan].”

See

CAT NMS Plan, at Section 1.1.

See

CAT NMS Plan, at Appendix D, Section 3.

The “CAT Order ID” is “a unique order identifier or series of unique order identifiers that allows the central repository to efficiently and accurately link all reportable events for an order, and all orders that result from the aggregation or disaggregation of such order.”

See

17 CFR 242.613(j)(1);

See also

November 2023 Order, at 77130 (noting that the conditional exemptive relief provided by the November 2023 Order continued to be in force for the other areas addressed therein, except as provided in Parts II.C-D of the November 2023 Order).

Pursuant to the Interim CAT-Order-ID Amendment, the phrase “lifecycle linkages” would be deleted from a bullet regarding what is required by Noon Eastern Time T+1, in Section 6.1 of Appendix D of the CAT NMS Plan.

Similarly, the phrase “Life Cycle Linkage” would be deleted from Figure A in Section 6.1 of Appendix D of the CAT NMS Plan, which currently states: “12:00 PM ET T+1 Initial Validation, Life Cycle Linkage, Communication of Errors.”

These changes would eliminate language in Section 6.1 of Appendix D of the CAT NMS Plan requiring life cycle linkage on T+1 and in advance of the provision of final CAT-Order-ID processing and linkage. The Interim CAT-Order-ID-Amendment would also include a revision to Section 6.1 of Appendix D of the CAT NMS Plan, to state that the data made available to Participant regulatory staff and the SEC on T+6 must not only be corrected but also linked.

See

Notice, at 61511.

See id.

Pursuant to the Data Availability Amendment, discussed

infra

Part III.F, final CAT-Order-IDs and the processing of corrected and linked data would be required on T+6 instead of T+5 as previously required by the Plan.

See also

Notice, at 61524-26.

Pursuant to the Interim CAT-Order-ID Amendment, the Participants propose to amend the CAT NMS Plan to require the Plan Processor to create and make available interim CAT-Order-IDs upon the request of certain Commission staff.

Specifically, a new provision would be added to Section 6.1 of Appendix D of the CAT NMS Plan stating that, “[u]pon request of a senior officer of the SEC's Division of Trading and Markets, the SEC's Division of Enforcement, or the SEC's Division of Examinations to CAT LLC, the Plan Processor shall be directed to create an interim CAT-Order-ID and make it available to regulators.”

This provision would also state that the timing and cost of ad hoc runs of the interim CAT-Order-ID would be based on the number of trade dates and the data volumes to be processed in the request, but generally would be anticipated to be processed by T+2 at 9 p.m. ET if the request is received prior to T+2 at 4 a.m. ET, or within 14 hours of receiving the request if such request was received after T+2 at 4 a.m. ET.

See id.

at 61511. CAT LLC states that the Participants rely on the final CAT-Order-ID and do not require an interim CAT-Order-ID.

See id.

This provision differs from the condition relating to interim lifecycle linkages in the 2025 Cost Savings Exemptive Relief Order, which stated that, “[u]pon requests made by authorized regulatory users from the Participants or the Commission, the Plan Processor shall create interim CAT Order IDs for a specified trade date or dates and thereby provide linked lifecycles to regulators before T+5 at 8 a.m. Eastern Time.”

See

2025 Cost Savings Exemptive Relief Order, at 47855.

See

Notice, at 61511. The provision's description of the timing and cost of creating an interim CAT Order ID ad hoc is consistent with what the Commission understood would be the timing and cost when it issued the 2025 Cost Savings Exemptive Relief Order.

See

2025 Cost Savings Exemptive Relief Order, at 47855 n.29 (stating that while the Commission understands that the timing and cost of creating an interim CAT Order ID ad hoc may vary based on the number of trade dates and data volumes to be processed in the request, the Commission understands that interim CAT Order IDs can generally be created by T+2 at 9 p.m. Eastern Time if the request is received prior to T+2 at 4 a.m. Eastern Time, or within 14 hours of receiving the request if such request is received after T+2 at 4 a.m. Eastern Time).

CAT LLC states that the removal of the requirement to provide interim lifecycle linkages is consistent with the exemptive relief set forth in the 2025 Cost Savings Exemptive Order, and thus the estimated cost savings for the Interim CAT-Order-ID Amendment are the same as expected with regard to the implementation of the 2025 Cost Savings Exemptive Order related to interim linkage, specifically $2 to $3 million in estimated annual cost savings for cloud hosting services.

CAT LLC states that to implement the proposal, the Plan Processor has proposed a one-time change request fee of approximately $225,000, and the Plan Processor estimates that it would take approximately 6 to 8 weeks to fully implement the changes for the Interim CAT-Order-ID Amendment.

With respect to requests for interim CAT-Order-IDs, CAT LLC states that would it add a separate line item to its budget to reflect costs related to these requests and the estimated cost of an ad hoc interim CAT-Order-ID delivery could range from approximately $8,000 to $12,000, but ultimately would depend on various unknowns including the then-current availability of compute resources and the size of the data volumes to be processed in the request.

See

Notice, at 61511.

See id.

at 61512. CAT LLC states that one-time implementation costs will generally consist of Plan Processor labor costs associated with coding and software development, as well as any related cloud fees associated with the development, testing, and load testing of the proposed changes for the proposed amendment.

Id.

See id.

at 61511. CAT LLC states that this estimate includes compute and storage costs for daily ad hoc interim lifecycle processing and is based on demand rates for a typical day with average data volumes. CAT LLC states that the estimated number of authorized ad hoc runs per year that would be requested by the SEC cannot be predicted by CAT LLC or the Plan Processor.

Id.

Two commenters state that they support the Interim CAT-Order-ID Amendment.

One of these commenters states that it supports the Interim CAT-Order-ID Amendment, as well as the other amendments, based on the projected cost savings to the CAT system, and further states that these amendments would not impact the quality of CAT data, do not raise security concerns, and would not increase the compliance and operational costs for Industry Members.

See

Letter to Vanessa Countryman, Secretary, Commission, from Howard Meyerson, Managing Director, Financial Information Forum (“FIF”), dated Feb. 10, 2026 (“FIF February 2026 Letter”), at 2, 4; Letter to Vanessa Countryman, Secretary, Commission, from Katie Kolchin, CFA, Managing Director, Head of Equity & Options Market Structure and Joseph Corcoran, Managing Director & Associate General Counsel, Securities Industry and Financial Markets Association (“SIFMA”), dated March 12, 2026 (“SIFMA March 2026 Letter”), at 6-7. Both these commenters also previously submitted a comment letter stating that the commenter needed additional time to finalize and submit their comment letter in response to the Notice.

See

Letter to Vanessa Countryman, Secretary, Commission, from Howard Meyerson, Managing Director, FIF, dated January 29, 2026; Letter to Vanessa Countryman Secretary, Commission, from Joseph Corcoran, Managing Director & Associate General Counsel, SIFMA, dated January 30, 2026.

See

FIF February 2026 Letter, at 4.

Timely access to linked data has been and continues to be one of the regulatory goals of Rule 613 and the CAT NMS Plan. Even after the Interim CAT-Order-ID Amendment is implemented, regulators will be able to access linked and corrected audit trail data by T+6 in the regular course, which should generally continue to be faster than was possible before the CAT existed.

CAT LLC represents that the Participants rely on the final CAT-Order-ID and do not require an interim CAT-Order-ID, and that the Participants do not believe that elimination of the interim CAT-Order-ID would impact their regulatory programs.

The Interim CAT-Order-ID Amendment does not impact the availability of the final CAT-

Order-ID which reflects corrections to errors that have been corrected.

See

CAT NMS Plan Approval Order, at 84783 (noting that OATS Data was not available until T+8). Final CAT-Order-IDs would be available at T+6, and not T+5, pursuant to changes to the CAT NMS Plan the Commission is approving in the “Data Availability Amendment,”

see infra

Part III.F.

See

Notice, at 61511.

See id.

The modification to make clear that final CAT Data must be both corrected and linked is appropriate and codifies and clarifies existing practice.

Id.

In the absence of interim CAT-Order-IDs, it is important that the Plan Processor continue to both correct and link final CAT-Order-IDs to ensure that such data is sufficiently complete and accurate for regulatory use.

Moreover, the Participants propose to amend the CAT NMS Plan to provide that the Commission will be able to request the creation of an interim CAT-Order-ID from the Plan Processor before T+6, as well as to access and analyze raw unprocessed data between T+2 at 8 a.m. Eastern Time and T+5 at 8 a.m. Eastern Time,

which functionality should continue to enable regulatory users to expeditiously review data as needed, albeit slightly slower than is currently possible.

See

proposed Section 6.1 of Appendix D of the CAT NMS Plan.

The proposed requirements for requesting ad hoc interim CAT-Order-ID in the Interim CAT-Order-ID Amendment differ from what was provided for in the 2025 Cost Savings Exemptive Relief Order.

See supra

note 56; 2025 Cost Savings Exemptive Relief Order, at 47855.

For the reasons discussed below, the Commission deems it appropriate to modify the Interim CAT-Order-ID Amendment so that it does not define which Commission staff are able to request ad hoc linkage processing.

The Commission is not a party to the Plan. By statute, the Commission is the regulator of the Participants, and an NMS Plan should not dictate how the Commission carries out its regulatory oversight. The Commission is therefore modifying the Interim CAT-Order-ID Amendment to remove the proposed limitation on which Commission personnel have authority to initiate ad hoc requests. The Commission is committed to ensuring that meaningful controls and safeguards are in place regarding who will have authority to initiate ad hoc requests and will appropriately limit the Commission personnel and anticipates that the Participants would do the same for their regulatory users.

CAT LLC states that the Interim CAT-Order-ID Amendment “is consistent with and would codify the exemptive relief related to the interim CAT-Order-ID as set forth in the 2025 Cost Savings Exemptive Order,”

see

Notice, at 61510, but the 2025 Cost Savings Exemptive Relief Order states that one of the conditions of exemptive relief states that, [u]pon requests made by authorized regulatory users from the Participants or the Commission, the Plan Processor shall create interim CAT Order IDs for a specified trade date or dates and thereby provide linked lifecycles to regulators before T+5 at 8 a.m. Eastern Time.”

See

2025 Cost Savings Exemptive Relief Order, at 47855.

Additionally, the Commission deems it appropriate to modify the CAT NMS Plan to allow for ad hoc requests for interim CAT-Order-IDs to be submitted by Participant regulatory users. As discussed above, timely access was one of the regulatory goals of Rule 613 and the CAT NMS Plan. While CAT LLC represented that the Participants do not require an interim CAT-Order-ID, to preserve the Participants' timely access to linked data in the event it is needed, the CAT NMS Plan should also allow for ad hoc requests for interim CAT-Order-IDs to be submitted by Participant regulatory users. The Commission also therefore deems it appropriate to modify the Interim CAT-Order-ID Amendment to require the Plan Processor to create and make available interim CAT-Order-IDs upon request from the Participants or the Commission, in a manner more consistent with the 2025 Cost Savings Exemptive Relief Order.

The Interim CAT-Order-ID Amendment, as modified and described below, will preserve the core regulatory benefits of Rule 613 and the CAT NMS Plan, while enabling the Participants to realize meaningful cost savings by avoiding the substantial cost of delivering interim CAT-Order-IDs on a regular basis. Specifically, the Interim CAT-Order-ID Amendment, as modified by the Commission, will allow regulators to request linked data from the Plan Processor before T+5, as well as to access and analyze raw unprocessed data between T+2 at 8 a.m. Eastern Time and T+5 at 8 a.m. Eastern Time, which functionality should continue to enable regulatory users to effectively and expeditiously review data in the case of a major market event, albeit slightly slower than is currently possible.

Specifically, in the new proposed paragraph to Section 6.1 of Appendix D of the CAT NMS Plan within the Interim CAT-Order-ID Amendment, the Commission is removing language limiting the provision to requests “of a senior officer of the SEC's Division of Trading and Markets, the SEC's Division of Enforcement, or the SEC's Division of Examinations to CAT LLC,” and adding new text so that the first clause of the paragraph reads: “Upon requests made by authorized regulatory users from the Participants or the Commission.” In comparison to proposed Section 6.1 of Appendix D of the CAT NMS Plan in the Proposed Amendment, the following changes would apply, with deletions shown through [brackets], and additions shown with

italics:

Upon request

s made by authorized regulatory users from the Participants or the Commission

[of a senior officer of the SEC's Division of Trading and Markets, the SEC's Division of Enforcement, or the SEC's Division of Examinations to CAT LLC], the Plan Processor shall be directed to create an interim CAT-Order-ID and make it available to regulators. The timing and cost of ad hoc runs of the interim CAT-Order-ID would be based on the number of trade dates and the data volumes to be processed in the request, but generally would be anticipated to be processed by T+2 at 9 p.m. ET if the request is received prior to T+2 at 4 a.m. ET, or within 14 hours of receiving the request if such request was received after T+2 at 4 a.m. ET.

B. Data Storage Amendment

The Data Storage Amendment proposes to amend the CAT NMS Plan to permit the Plan Processor to delete (i) all CAT Data older than three years (other than CAT Data with a shorter retention period as described below); (ii) OMM Quotes older than six months; (iii) Interim Operational Data older than 15 days; and (iv) quote and NBBO data included in the SIP Data

from the OPRA Plan or any successor SIP

for Listed Options

(“Options SIP Data”) older than six months.

CAT LLC states that the Data Storage Amendment expands upon the exemptive relief in the 2025 Cost Savings Exemptive Relief Order by: (i) deleting all CAT Data older than three years, rather than older than five years; (ii) deleting OMM Quotes older than six months, rather than older than one year; and (iii) deleting Options SIP Data older than six months, rather than older than five years.

See

Section 6.5 of the CAT NMS Plan.

See

Section 1.1 of the CAT NMS Plan.

See

Section 1.1 of the CAT NMS Plan.

See

Notice, at 61512-17.

See

Notice, at 61513.

Several data storage and retention requirements govern the Participants' storage of data and/or data stored within the CAT. First, the Participants are subject to the storage requirements of Rule 17a-1, which states, among other things, that “[e]very national securities exchange [and] national securities association . . . shall keep and preserve at least one copy of all documents, including all correspondence, memoranda, papers, books, notices, accounts, and other such records as shall be made or received by it in the course of its business as such and in the conduct of its self-regulatory activity,” and that “[e]very national securities exchange [and] national securities association . . . shall keep such documents for a period of not less than five years, the first two years in an

easily accessible place, subject to the destruction and disposition provisions of Rule 17a-6.”

See

17 CFR 240.17a-1.

Second, Rule 613(e)(8) states that the CAT NMS Plan must require the Central Repository to “retain the information collected pursuant to paragraph (c)(7) and (e)(7) . . . in a convenient and usable standard electronic data format that is directly available and searchable electronically without any manual intervention for a period of not less than five years.”

See

17 CFR 242.613(e)(8).

The CAT NMS Plan itself imposes several storage requirements with respect to CAT Data, including requirements in Section 6.5(b) that the Central Repository retain “the information collected pursuant to paragraphs (c)(7) and (e)(7) of SEC Rule 613 in a convenient and usable standard electronic data format that is directly available and searchable electronically without any manual intervention by the Plan Processor for a period of not less than six (6) years.”

Additionally, pursuant to Section 1.4 of Appendix D of the CAT NMS Plan, “[t]he Plan Processor must develop a formal record retention policy and program for the CAT, to be approved by the Operating Committee, which will, at a minimum . . . [m]ake data directly available and searchable electronically without manual intervention for at least six years . . . .” Section 6.3 of Appendix D of the CAT NMS Plan provides an exception to these requirements for several kinds of data, including “Interim Operational Data older than 15 days,”

which may be retained in an archive storage tier, meaning such data is not directly available and searchable without manual intervention.

See

CAT NMS Plan, at Section 6.5(d). Section 6.1(d)(i) of the CAT NMS Plan also requires the Plan Processor to comply with the recordkeeping requirements of Rule 613(e)(8).

“Interim Operational Data” is defined as “all processed, validated and unlinked data made available to regulators by T+1 at 12:00 p.m. ET and all iterations of processed data made available to regulators between T+1 and T+5, but excludes the final version of corrected data that is made available at T+5 at 8:00 a.m. ET,” and “[f]or the avoidance of doubt, `Interim Operational Data' does not include processed data relating to Options Market Maker quotes in Listed Options made available to regulators by T+1 at 12:00 p.m. ET.”

See

CAT NMS Plan, at Appendix D, Section 6.3.

The CAT NMS Plan states that the Plan Processor will restore archived data to an accessible storage tier upon request to the CAT Help Desk by an authorized regulatory user from the Participants or a senior officer from the SEC.

See

CAT NMS Plan, Appendix D, Section 6.3.

In the 2025 Cost Savings Exemptive Relief Order, the Commission granted conditional exemptive relief from the above-described requirements of Rule 17a-1,

Rule 613(e)(8), Sections 6.1(d)(i) and 6.5(b) of the CAT NMS Plan, and Sections 1.4 and 6.3 of Appendix D of the CAT NMS Plan, to the extent necessary to allow the Participants to: (i) delete all CAT Data older than five years; (ii) move CAT Data older than three years to a more cost-effective storage tier (

i.e.,

a tier requiring some “manual intervention” to retrieve data), subject to the condition that the Plan Processor will restore archived CAT Data which is older than three years old to an accessible storage tier upon request to the CAT Help Desk by an authorized regulatory user from the Participants or from the SEC;

(iii) delete OMM Quotes data after one year from the CAT System; and (iv) delete Interim Operational Data older than 15 days.

Because the CAT is a facility of the Participants, it is subject to the record-keeping provisions of Rule 17a-1, and so the Participants required exemptive relief from Rule 17a-1 to delete OMM Quotes data after one year from the CAT System and to delete Interim Operational Data older than 15 days.

See

2025 Cost Savings Exemptive Relief Order, at 47858. The Commission stated in the 2025 Cost Savings Exemptive Relief Order that conditions enabling the Participants to delete all CAT Data older than five years and/or to move CAT Data older than three years to a more cost-effective storage tier are already consistent with or more generous than Rule 17a-1, although they are more lenient than the requirements otherwise contained in Rule 613 and/or the CAT NMS Plan.

See id.

at 47858 n.54.

CAT Data is currently stored in four storage tiers: S3 Frequent Access, S3 Infrequent Access, S3 Instant Archive Access, and S3 Glacier Deep Archive. The 2025 Cost Savings Exemptive Relief Order permits the Participants to move all CAT Data older than three years to a storage tier like S3 Glacier Deep Archive.

Id.

at 47858 n.55.

See id.

at 47857-58.

Pursuant to the Data Storage Amendment, CAT LLC proposes to change Section 6.1(d)(i) of the CAT NMS Plan to replace the requirement to comply with the recordkeeping requirements of Rule 613(e)(8) with a requirement to instead comply with the recordkeeping requirements of Section 6.5 and Appendix D.

CAT LLC proposes to amend Section 6.5(b)(i) of the CAT NMS Plan to permit the Plan Processor to delete CAT Data older than three years, by amending the first sentence of the provision to state that CAT Data will be retained for a period of not less than three years, and in a convenient and usable standard electronic data format that is directly available and searchable electronically without any manual intervention by the Plan Processor, subject to the exceptions in Section 3.4, Section 6.3 and Section 6.4 of Appendix D.

Pursuant to this change, CAT LLC proposes to remove references in that sentence to the information collected pursuant to paragraphs (c)(7) and (e)(7) of Rule 613 and language requiring CAT Data be stored by the Plan Processor for a period of not less than six years.

See

Notice, at 61514. Rule 613(e)(8) requires, among other things, that CAT data be made “directly available and searchable electronically without any manual intervention for a period of not less than five years.” 17 CFR 242.613(e)(8).

See id.

The Data Savings Amendment also includes changes to Sections 1.4, 3.4, and 6.3 of Appendix D of the CAT NMS Plan.

Section 1.4 of Appendix D's requirement for a formal record retention policy and program for the CAT would be changed to state that the policy and program must “retain CAT Data for a period of not less than three (3) years and make it directly available and searchable electronically without manual intervention, subject to the exceptions in Section 3.4, Section 6.3 and Section 6.4 of Appendix D,” instead of stating that the policy and program must make data directly available and searchable electronically without manual intervention for at least six years, subject to the exceptions in Section 6.3 of Appendix D.

Section 3.4 of Appendix D would be changed to include a sentence stating, “[n]otwithstanding any other provision of the CAT NMS Plan, this Appendix D, or Exchange Act Rule 17a-1, Options Market Maker quotes in Listed Options older than six months may be deleted by the Plan Processor.”

Section 6.3 of Appendix D of the CAT NMS Plan, regarding exceptions to data availability requirements, would be changed to delete a provision allowing for the archiving of Interim Operational Data older than 15 days, because Section 6.4 of Appendix D, discussed below, would instead allow for deletion of such data.

See id.

at 61514-15.

See id.

at 61515.

See id.

The Data Storage Amendment would also establish a new Proposed Section 6.4 of Appendix D of the CAT NMS Plan, which would describe the reduced retention periods for Interim Operational Data and Options SIP Data.

Specifically, proposed Section 6.4 of Appendix D would state that, “[n]otwithstanding any other provision of the CAT NMS Plan, this Appendix D, or Exchange Act Rule 17a-1, the following may be deleted from the CAT by the Plan Processor,” Interim Operational Data older than 15 days and Options SIP Data older than six

months.

Proposed Section 6.4 of Appendix D would further state that “Interim Operational Data” means all processed, validated and unlinked data made available to regulators by T+2 at 8:00 a.m. ET and all iterations of processed data made available to regulators between T+2 and T+6, but excludes the final version of corrected data that is made available by T+6 at 8:00 a.m. ET.

Proposed Section 6.4 of Appendix D would also state that “Options SIP Data” means quote and NBBO data included in the SIP Data from the OPRA Plan or any successor SIP for Listed Options.

See id.

Proposed Section 6.4 of Appendix D of the CAT NMS Plan would also state that, for the avoidance of doubt, “Interim Operational Data” does not include processed data relating to Options Market quotes in Listed Options made available to regulators by T+2 at 8:00 a.m. ET.

See id.

CAT LLC states that the Data Savings Amendment would allow CAT LLC to achieve an estimated $23.5 to $32 million in annual cost savings for cloud hosting services.

CAT LLC states that the Data Storage Amendment expands upon the substance of the exemptive relief related to data storage and retention granted by the Commission in the 2025 Cost Savings Exemptive Order, and that this expansion increases the anticipated cost savings related to data storage and retention by approximately $6.5 to $9 million as compared to the 2025 Cost Savings Exemptive Order.

CAT LLC states that to implement the Data Storage Amendment, the Plan Processor has proposed a one-time change request setting forth an implementation fee of approximately $165,000-$265,000, and that the Plan Processor estimates that it would take approximately three to four months to fully implement the changes for the Data Storage Amendment.

See id.

CAT LLC provides a range of estimated reduction in cloud hosting fees for each individual component of the Data Storage Amendment in the Notice.

See id.

at 61514.

See id.

at 61513.

See

Notice, at 61516. CAT LLC states that one-time implementation costs will generally consist of Plan Processor labor costs associated with coding and software development, as well as any related cloud fees associated with the development, testing, and load testing of the proposed changes for the proposed amendment.

Id.

One commenter states that it supports the Data Storage Amendment, but with a requested change.

The commenter states that it supports the Data Storage Amendment, as well as the other amendments, based on the projected cost savings to the CAT system, and further states that these amendments would not impact the quality of CAT data, do not raise security concerns, and would not increase the compliance and operational costs for Industry Members.

However, the commenter states that it supports the proposal to delete CAT data older than three years, provided that this change would not (i) impede the retirement of Electronic Blue Sheets (“EBS”) or (ii) result in a material increase in the number of EBS or equivalent informational requests.

The commenter estimates that the incremental savings from removing CAT data after three years as compared to removing CAT data after five years and moving CAT data to lower cost storage after three years is between $2.0 million and $2.8 million and requesting that CAT LLC provide its own estimate of the incremental costs savings as well as any information it can provide as to whether the deletion of CAT data after three years would (i) impede the retirement of EBS or (ii) result in a material increase in the number of EBS or equivalent informational requests.

See

FIF February 2026 Letter, at 2, 4.

See id.

at 4.

See id.

In the Notice, CAT LLC states that the Data Storage Amendment would reduce costs with limited regulatory impact and without having an adverse impact on Industry Members or their costs. See Notice, at 61517.

See

Letter to Vanessa Countryman, Secretary, Commission, from Howard Meyerson, Managing Director, FIF, dated Mar. 2, 2026, (“FIF March 2026 Letter”) at 2.

The commenter also asks that in connection with approving the Data Storage Amendment, that the Commission provide a safe-harbor exemption (or direct the SROs to adopt rules providing a safe-harbor exemption) that Industry Members similarly are not required to retain CAT data that is older than three years.

100

This commenter states that CAT LLC previously provided guidance that, according to each of the Participant's CAT compliance rules, information required to be reported to the CAT must be maintained in accordance with Rule 17a-4(b), and stated that this rule states that these records must be preserved for at least three years, the first two years in an accessible place.

101

The commenter states that the guidance appears to apply to the underlying data being reported, and it is not clear whether this guidance also applies to the CAT submissions themselves, and requests that the Commission provide guidance specifically with respect to CAT submissions, as requested above.

102

100

See

FIF February 2026 Letter, at 4.

101

See id.

102

See id.

at 4 (citing FINRA CAT, LLC, CAT FAQ A23, available at:

https://catnmsplan.com/faq

Another commenter states that it has concerns related to the Data Storage Amendment, but states that it is pleased to see that the Participants sought to further the cost reduction measures from the 2025 Cost Savings Exemptive Order.

103

The commenter states that it supports efforts to reduce the costs associated with CAT data older than three years, but states that any modification to the CAT data retention framework should be evaluated holistically to ensure that apparent savings at the Plan level do not result in cost-shifting to Industry Members or undermine the retirement of legacy systems such as EBS, and that the Data Storage Amendment would not produce net cost savings if reducing CAT retention periods leads to increased regulatory requests directed to Industry Members for historical data or necessitates the continued maintenance of EBS to fill potential data gaps.

104

The commenter asks the Commission to carefully assess all available cost-reduction alternatives, including whether historical CAT data could be migrated to a lower-cost storage tier—such as a cold storage environment—where the data would remain available to regulators when necessary, subject to a reasonable retrieval delay.

105

103

See

SIFMA March 2026 Letter at 5-6. The commenter notes that the Data Storage Amendment would lead to the highest amount of annual CAT cost savings of any of the proposed cost saving measures included in the Proposed Amendment.

Id.

at 6.

104

See id.

105

See id.

The commenter states that such an approach could preserve regulatory access and support the retirement of duplicative systems, while avoiding unintended operational and compliance burdens on Industry Members.

Id.

CAT LLC subsequently submitted a comment letter providing a breakdown of the incremental savings that would be achieved for each component of the Data Storage Amendment as compared to the 2025 Cost Savings Exemptive Relief Order.

106

With respect to the commenter's request regarding the incremental savings from removing CAT data after three years as compared to removing CAT data after five years and moving CAT data to lower cost storage after three years, CAT LLC states that the proposal to delete CAT Data older than three years would result in an estimated reduction in cloud hosting fees of $8.8 to $12 million, while the 2025 Cost Savings Exemptive Relief Order allowing CAT Data older than three years (but no longer than five years) be moved to a more cost-effective

storage tier would result in an estimated reduction in cloud hosting fees of $7.2 to $9.8 million.

107

106

See

Letter to Vanessa Countryman, Secretary, Commission, from Robert Walley, CAT NMS Plan Operating Committee Chair, CAT LLC, dated March 10, 2026 (“CAT LLC March 2026 Response Letter”), at 4-6.

107

See id.

at 4. CAT LLC March 2026 Response Letter also contains differences in the estimated reduction in cloud hosting fees between the different elements of the Data Storage Amendment and the 2025 Cost Savings Exemptive Order, showing a total estimated reduction in cloud hosting fees of $23.5 to $32 million for the Proposed Amendment as compared to estimated savings of $17.2 to $23.4 million for the data storage related exemptive relief in the 2025 Cost Savings Exemptive Order.

Id.

The proposed deletion of CAT Data older than three years will impact regulatory efficiency to the extent regulators need access to the deleted data and seek to obtain it elsewhere.

108

The Commission previously stated that the first three years of CAT Data will be more frequently accessed and needed by regulatory users based on its experience in using the CAT and this view remains unchanged. This does not mean that CAT Data older than three years is not needed.

109

Regulatory staff access trading data older than three years in the context of examinations, enforcement, and economic analysis. For example, the statute of limitations for federal securities fraud is generally five years from the date of the alleged fraud,

110

and thus regulators need to access and analyze trading activity that is older than three years. To acquire the relevant data after implementation of the Data Storage Amendment, regulators will need to either download and maintain CAT Data older than three years, whether in whole or in some abbreviated or summarized form, and/or request information directly from market participants, such as exchange market data or trade data from Industry Members through EBS or other processes.

111

108

When the Commission issued the 2025 Cost Savings Exemptive Order, it considered this need when providing exemptive relief allowing for the deletion of CAT Data older than five years, with CAT Data older than three years to be stored in a cheaper, slower archival method, rather than permitting deletion of all CAT Data after three years as is being approved.

See

2025 Cost Savings Exemptive Order, at 47858.

109

See

Notice, at 61516 (citing 2025 Cost Savings Exemptive Order, at 47858). CAT LLC states that OTQT usage metrics (via DIVER) from January to November 2025 demonstrate that only 2% of DIVER requests (750 out of 38,028 requests) were for trade dates older than three years.

See id.

110

See

29 U.S.C. 2462.

111

CAT LLC states that the Participants do not anticipate generally needing CAT Data older than three years to support their regulatory programs.

See id.

As noted above, one commenter supports the deletion of CAT Data older than three years provided this change would not (i) impede the retirement of EBS or (ii) result in a material increase in the number of EBS or equivalent informational requests.

112

The deletion of CAT Data older than three years is not anticipated to result in a significant increase in the number of EBS or other informational requests given the more limited regulatory need for this older data. To the extent there is an increase in these requests, it is justified by the cost savings from the amendment.

113

112

One commenter supports the proposal to delete CAT data older than three years provided that, among other things, it does not result in a material increase in the number of EBS or equivalent informational requests.

See

FIF February 2026 Letter, at 6.

See also

FIF March 2026 Letter, at 2.

113

CAT LLC does not specifically state what would be the estimated savings of deleting CAT Data older than three years versus storing CAT Data older than three years and up to five years in lower cost storage. The commenter estimated the difference to be between $2.0 million and $2.8 million based on the Notice, and asked CAT LLC to provide its own estimate.

See

FIF March 2026 Letter, at 2.

As discussed above, a commenter requests a “safe-harbor exemption” or that the Commission direct the SROs to adopt rules providing a safe-harbor exemption that Industry Members are not required to retain CAT data that is older than three years.

114

However, such an exemption is not necessary because the Proposed Amendment does not change the obligations of Industry Members to maintain records pursuant to Rule 17a-4,

115

and does not subject any Industry Member data to more lengthy record retention time periods than currently required. The Data Storage Amendment only changes the obligations relating to the storage of CAT Data within the CAT itself. Rule 17a-4 will continue to require each Industry Member to preserve certain records for certain time periods.

116

Information required to be reported to the CAT must be maintained in accordance with Rule 17a-4(b)—the Data Storage Amendment does not change any Industry Member record-keeping obligations.

114

See

FIF February 2026 Letter, at 6. The commenter states that its members “request that the Commission provide guidance specifically with respect to CAT submissions.”

Id.

115

See

17 CFR 240.17a-4.

See also

CAT FAQ A23, available at:

https://catnmsplan.com/faq.

As this guidance is from the Participants and FINRA CAT, LLC, the Commission anticipates CAT LLC will provide further guidance to Industry Members. To the extent appropriate or needed, this guidance can be revisited.

116

See

17 CFR 240.17a-3; 17 CFR 240.17a-4.

The Data Storage Amendment would provide significant cost savings. Storage costs are a significant component of overall CAT costs, with the amount of information required to be stored by the Plan Processor far greater than originally anticipated at the adoption of the CAT NMS Plan.

117

The Data Storage Amendment targets two types of data: (1) CAT Data older than three years and (2) three specific subsets of CAT Data that collectively drive a substantial portion of CAT costs.

118

These subsets of CAT Data, specifically OMM Quotes, Options SIP Data, and Interim Operational Data, incur substantial storage costs. Limiting the amount of these two types of data stored in the CAT is reasonable in light of the substantial cost savings and limited regulatory value of this data in comparison to other types of CAT Data and the fact that the relevant CAT Data will remain available from other sources,

119

albeit slightly less efficiently than currently possible.

117

CAT LLC states that the Plan Processor projects that cumulative storage will be approximately 820 to 830 petabytes for 2025, more than 28 times the original estimate of 29 petabytes of raw, uncompressed data in the CAT NMS Plan Approval Order.

See

Notice, at 61515.

118

CAT LLC states that OMM Quotes are the single largest data source for the CAT, comprising approximately 98% of all Options Exchange events and approximately 44% of all transaction volume.

See id.

at 61516. In addition, CAT LLC states that Options SIP Data represents 25% of storage costs.

Id.

119

For example, the Participants state that they have access to Options SIP Data through other sources outside of CAT, and therefore it would not impact Participant regulatory programs if Options SIP Data older than 6 months was removed from the CAT because the Participants can access this data through other means.

See

CAT LLC March 2026 Response Letter, at 6.

Additionally, the proposed replacement of language in Sections 6.1(d)(i) and 6.5(b)(i) of the CAT NMS Plan referencing Rule 613 would eliminate confusion or perceived inconsistency regarding legacy language in Rule 613 For proposed Section 6.1, replacing the reference to Rule 613(e)(8) with a reference to Section 6.5 and Appendix D directs readers to sections of the CAT NMS Plan which are substantially more descriptive regarding the recordkeeping requirements relating to CAT Data, while removing a reference to language in Rule 613(e)(8) that would otherwise conflict with the Data Storage Amendment, specifically the requirement of Rule 613(e)(8) to require the central repository to retain certain information in a convenient and usable standard electronic data format that is directly available and searchable electronically without any manual intervention for a period of not less than five years.

120

The deletion of the reference to “the information collected pursuant to paragraphs (c)(7) and (e)(7) of SEC Rule 613” would also help avoid confusion.

121

120

See

17 CFR 242.613(e)(8).

121

See

17 CFR 242.613(c)(7) and (e)(7).

CAT LLC requests that, to the extent the Commission deems it necessary to grant exemptive relief from the recordkeeping and data retention requirements of Rule 17a-1 or any other provision under the Exchange Act or the CAT NMS Plan in order to effectuate this proposal, that the Commission utilize its authority under Section 36(a)(1) of the Exchange Act

122

and Rule 608(e) of Regulation NMS

123

to grant such exemptive relief. Such relief is necessary in order to effectuate the Proposed Amendment, as Rule 17a-1 would otherwise require the customer data and information in CAIS be preserved by the Participants.

124

The Commission finds that it is appropriate in the public interest and consistent with the protection of investors under Section 36 of the Exchange Act,

125

as well as consistent with the public interest, the protection of investors, the maintenance of fair and orderly markets and the removal of impediments to, and the perfection of, a national market system under Rule 608(e) under the Exchange Act,

126

to grant relief that exempts each Participant from the recordkeeping and data retention requirements for CAT Data that would no longer be required to be retained by the Plan Processor under the Data Storage Amendment and that otherwise would apply as set forth in Rule 17a-1 under the Exchange Act. This relief applies only to the Participants' and the Plan Processor's obligations to keep and preserve specific CAT Data in the CAT, and does not apply to any information or records that are required to be kept and preserved outside of the CAT. For example, if information from CAT is used in systems outside the CAT, such as a Participant's surveillance systems, the relief would not apply to such information.

122

See

15 U.S.C. 78mm(a)(1), which provides, in relevant part, that the “Commission, by rule, regulation, or order, may conditionally or unconditionally exempt any person, security, or transaction, or any class or classes of persons, securities, or transactions, from any provision or provisions of this title or of any rule or regulation thereunder, to the extent that such exemption is necessary or appropriate in the public interest, and is consistent with the protection of investors.”

123

See

17 CFR 242.608(e), which provides that “[t]he Commission may exempt from the provisions of this section, either unconditionally or on specified terms and conditions, any self-regulatory organization, member thereof, or specified security, if the Commission determines that such exemption is consistent with the public interest, the protection of investors, the maintenance of fair and orderly markets and the removal of impediments to, and perfection of the mechanisms of, a national market system.”

124

Rule 17a-1 requires national securities exchanges and national securities associations, among others, to keep and preserve at least one copy of all documents, including all correspondence, memoranda, papers, books, notices, accounts, and other such records as shall be made or received by it in the course of its business as such and in the conduct of its self-regulatory activity. 17 CFR 240.17a-1.

125

17 CFR 242.608(e).

126

17 CFR 240.17a-1.

In connection with this exemption, the Commission is modifying, pursuant to Rule 608(b)(2),

127

proposed Section 3.4, and Sections 6.3 and 6.4 of Appendix D of the CAT NMS Plan to remove references to Exchange Act Rule 17a-1. As proposed, each of these Sections would state “[n]otwithstanding any other provision of the CAT NMS Plan, this Appendix D,

or Exchange Act

Rule 17a-1.” (emphasis added). However, an NMS plan cannot void or otherwise modify the requirements of the Exchange Act. The CAT NMS plan is a contractual agreement among the Participants created pursuant to the Exchange Act and, absent an exemption or other relief, the NMS Plan and the Participants themselves are subject to applicable Exchange Act requirements. In addition, references to Exchange Act Rule 17a-1 in the CAT NMS Plan are unnecessary given the exemptive relief granted above and previously by the Commission. For these reasons, the Commission deems it appropriate to modify Section 3.4 of the CAT NMS Plan, and Sections 6.3 and 6.4 of Appendix D of the CAT NMS Plan, to remove the references to Exchange Act Rule 17a-1.

127

17 CFR 242.608(b)(2).

Specifically, the Commission is modifying the first sentence of Section 3.4 of Appendix D of the CAT NMS Plan such that it will state: “The provisions of this section shall govern the processing and storage of Options Market Maker quotes in Listed Options and shall override any conflicting provisions in the CAT NMS Plan or this Appendix D.” In addition, the Commission is modifying the sentence proposed to be added to Section 3.4 of Appendix D of the CAT NMS Plan in a similar fashion, such that it will read: “Notwithstanding any other provision of the CAT NMS Plan or this Appendix D, Options Market Maker quotes in Listed Options older than six months may be deleted by the Plan Processor.” In comparison to proposed Section 3.4 of Appendix D of the CAT NMS Plan in the Proposed Amendment, the following changes would apply, with deletions shown through [brackets], and additions shown with

italics:

3.4 Requirements for Options Market Maker Quotes in Listed Options

The provisions of this section shall govern the processing and storage of Options Market Maker quotes in Listed Options and shall override any conflicting provisions in the CAT NMS Plan[,]

this Appendix D[, or Exchange Act Rule 17a-1].

Notwithstanding any other provision of the CAT NMS Plan[,]

this Appendix D[, or Exchange Act Rule 17a-1], Options Market Maker quotes in Listed Options older than six months may be deleted by the Plan Processor.

The Commission is modifying the first sentence of Section 6.3 of Appendix D of the CAT NMS Plan such that it will state: “Notwithstanding any other provision of the CAT NMS Plan or this Appendix D, the following types of data may be retained in an archive storage tier.” In comparison to proposed Section 6.3 of Appendix D of the CAT NMS Plan in the Proposed Amendment, the following changes would apply, with deletions shown through [brackets], and additions shown with

italics:

6.3 Exceptions to Data Availability Requirements

Notwithstanding any other provision of the CAT NMS Plan[,]

this Appendix D[, or Exchange Act Rule 17a-1], the following types of data may be retained in an archive storage tier. Archived data is not directly available and searchable electronically without manual intervention and will not be subject to any query tool performance requirements until it is restored to an accessible storage tier. The Plan Processor will restore archived data to an accessible storage tier upon request to the CAT Help Desk by an authorized regulatory user from the Participants or a senior officer from the SEC.

The Commission is modifying the first sentence of Section 6.4 of the Appendix D of the CAT NMS Plan such that it will state: “Notwithstanding any other provision of the CAT NMS or this Appendix D, the following may be deleted from the CAT by the Plan Processor:”

In comparison to proposed Section 6.4 of Appendix D of the CAT NMS Plan in the Proposed Amendment, the following changes would apply, with deletions shown through [brackets], and additions shown with

italics:

6.4 Retention of Interim Operational Data and Options SIP Data

Notwithstanding any other provision of the CAT NMS Plan[,]

this Appendix D[, or Exchange Act Rule 17a-1], the following may be deleted from the CAT by the Plan Processor:

C. Late Data Re-Processing Amendment

The Late Data Re-Processing Amendment proposes to amend the CAT NMS Plan to discontinue re-processing for all late or corrected data received after T+4 at 8 a.m. Eastern Time (“Late Reported Data”).

128

This would expand upon the substance of exemptive relief related to late data re-processing granted by the Commission in the 2025 Cost Savings Exemptive Order by eliminating all late-reprocessing.

129

128

See

Notice, at 61517.

129

See id.

Appendix D, Section 3 of the CAT NMS Plan requires that “[a]ll CAT Data reported to the Central Repository must be processed and assembled to create the complete lifecycle of each Reportable Event.”

130

The CAT NMS Plan sets a deadline of T+3 at 8 a.m. Eastern Time for the “[r]esubmission of corrected data” and a deadline of T+5 at 8 a.m. Eastern Time for the Plan Processor to make “[c]orrected data available to Participant regulatory staff and the SEC.”

131

For data corrections received after T+5, the CAT NMS Plan specifies that “Participants' regulatory staff and the SEC must be notified and informed as to how re-processing will be completed.”

132

130

“CAT Data” is defined as “data derived from Participant Data, Industry Member Data, SIP Data, and such other data as the Operating Committee may designate as `CAT Data' from time to time.”

See

CAT NMS Plan, at Section 1.1.

131

See

CAT NMS Plan, at Appendix D, Section 6.1.

132

See

CAT NMS Plan, at Appendix D, Section 6.2.

The processing of Late Reported Data has been the subject of previous exemptive relief. Pursuant to the November 2023 Order the Commission, among other things, granted exemptive relief from these requirements, subject to the following conditions:

133

See

November 2023 Order, at 77130-31.

• The Plan Processor was required to maintain its implementation of functionality that was approved by the Operating Committee on January 14, 2022 (the “Late to the Lifecycle process”) and on September 20, 2022 (the “Targeted Replay process”) (collectively, the “Enhanced Late to the Lifecycle process”). Prior to the implementation of this functionality, in the limited circumstances in which there was a missing link between two disjoined segments of an order lifecycle, new or corrected data would join only one of the pre-existing segments and would be assigned to only one of the relevant lifecycle CAT Order IDs for the disjoined segment and evaluated for further re-processing. Under the Enhanced Late to the Lifecycle process, all late records (

i.e.,

records received after T+5)

134

include the date of the correction and, if applicable, the record identifier of the record being corrected as part of normal re-processing. In addition, the late record became associated with all relevant lifecycles as part of normal re-processing, such that order event lifecycles may be associated with more than one CAT Order ID.

134

For the purposes of the November 2023 Order and this Order, references to data received after T+5, or to post-T+5 data, submissions, or reports, are to data received after T+4 at 8 a.m. Eastern Time.

See

November 2023 Order, at 77130.

• The Participants were required to approve a change order to adopt:

○ Functionality to create a lifecycle mapping which indicates all lifecycle associations made during the Enhanced Late to the Lifecycle process;

○ Functionality to present to regulatory users post-T+5 data in a manner substantially similar to how such data would have been represented if it had been reported prior to T+5, including by replicating and replaying records with enrichments impacted by post-T+5 submissions, creating updated enrichments, and persisting the replicated records within the underlying data (the “Full Replay process”); and

○ Functionality to enhance the OTQT, including the ability to include or exclude any records that were created or replaced as a result of the Full Replay process.

• The Plan Processor was required to schedule the Enhanced Late to the Lifecycle process and the Full Replay process to run weekly, such that late reported data received through Friday of the prior week are available for regulatory users on the following business day at 8 a.m. Eastern Time, absent extraordinary circumstances, for data within the prior 18 months. For data outside of this 18-month window, the Participants were required to schedule the Enhanced Late to the Lifecycle process and the Full Replay process to run no less frequently than quarterly.

135

See

November 2023 Order, at 77130-31.

In the 2025 Cost Savings Exemptive Relief Order the Commission granted further exemptive relief relating to the re-processing of Late Reported Data that superseded the conditional exemptive relief set forth in the November 2023 Order with respect to the re-processing of data received after T+5.

136

Specifically, the Commission granted conditional exemptive relief from the re-processing requirements for late records in Appendix D, sections 3, 6.1, and 6.2 of the CAT NMS Plan, subject to the following conditions:

137

136

See

2025 Cost Savings Exemptive Relief Order, at 47855-56. The Commission stated that the conditional exemptive relief provided by the November 2023 Order continued to be in force for the other areas addressed therein, except as provided in Parts II.A and II.C of the 2025 Cost Savings Exemptive Relief Order.

Id.

at 47856 n.39.

137

See id.

at 47856.

• The Plan Processor must maintain its implementation of the above-described Enhanced Late to the Lifecycle process for late records from trade dates within the prior 3 years. For data outside of this 3-year window, no re-processing is required.

• For all late records, the Plan Processor must run the above-described Enhanced Late to the Lifecycle process no less frequently than quarterly.

• The Plan Processor must maintain the above-described functionality that creates a lifecycle mapping which indicates all lifecycle associations made during the Enhanced Late to the Lifecycle process.

• Upon requests made by authorized regulatory users from the Participants or the Commission, the Plan Processor must perform the Full Replay process on specified data, such that late records received through Friday of the prior week are available for regulatory users on the following business day at 8 a.m. Eastern Time, absent extraordinary circumstances.

138

In the 2025 Cost Savings Exemptive Relief Order, the Commission stated that it expects that the timing and cost of performing the Full Replay process would likely vary based on the number of trade dates and data volumes to be processed in the request, as well as on the availability of compute resources.

Id.

at 47856 n.38. The Commission stated that although the Commission does not expect regulatory users to utilize the Full Replay process frequently, it may be appropriate for the Participants to budget for its potential use.

Id.

• For late records received after T+5 at 8 a.m. Eastern Time, the Plan Processor must continue to notify regulatory users how re-processing will be completed.

In the Late Data Re-Processing Amendment, CAT LLC proposes to amend Section 6.2 of Appendix D of the CAT NMS Plan to change the re-processing requirements for Late Reported Data.

139

Specifically, CAT LLC proposes to revise 6.2 of Appendix D of the CAT NMS Plan to state that “[n]otwithstanding any other requirements of the CAT NMS Plan, or the Exchange Act or the rules and regulations thereunder, records received after T+4 at 8:00 a.m. Eastern Time will not be subject to any re-processing and will be added to the audit trail without any lifecycle enrichments.”

140

CAT LLC also proposes to remove the requirement that “[i]f corrections are received after

T+5, Participants' regulatory staff and the SEC must be notified and informed as to how re-processing will be completed,” and the statement that “[t]he Operating Committee will be involved with decisions on how to re-process the data; however, this does not relieve the Plan Processor of notifying the Participants' regulatory staff and the SEC.”

141

139

See

Notice, at 61517-21.

140

See id.

at 61519.

141

See id.

CAT LLC states that with this proposed change, the Plan Processor will continue to provide data regarding late submissions to CAT Reporters and regulators and continue to make available summary statistics on late submission through its report card program.

142

Additionally, CAT LLC states that FINRA CAT will continue to publish detailed information regarding late submissions and other issues to regulators through its data issue search system, and to send summary emails describing new data issues to all query tool users on a weekly basis.

143

CAT LLC states that the distinction between trade date and submission date continues to be available on a record-by-record basis within the Central Repository and so regulators can identify and review late data submissions by leveraging summary statistics provided by the Plan Processor, by reviewing the catalog of data issues updated daily in the data issue search system, and by reviewing the underlying records themselves.

144

142

See id.;

Section 10.4 of Appendix D of the CAT NMS Plan (requiring compliance report cards to include the “[n]umber of transactions submitted later than reporting deadlines”).

143

See

Notice, at 61519 n.85 (citing Appendix C of the CAT NMS Plan at C-12).

144

See id.

at 61519.

CAT LLC states that it has seen substantial compliance with CAT reporting timelines, and that, for example, in the past year, only 0.82% of Reportable Events were reported late, and only 0.07% of Reportable Events required re-processing.

145

Through the first ten months of 2025, CAT LLC states that the vast majority of first-time “late” data (99.72%) is reported by T+4 8 a.m., and when firms submit repairs and corrections, most of the corrections and repairs (94.2%) are submitted beyond T+60, which indicates that changes to feedback timing would not dramatically impact how regulators perceive CAT Data when measured in the aggregate.

146

145

See id.

at 61520.

146

See id.

In addition, CAT LLC states that it understands that, with this proposed change, the Plan Processor would retain the ability to perform Late to the Lifecycle and Full Replay re-processing on an ad hoc basis if required for regulatory purposes.

147

CAT LLC states that it further understands that there would be no material impact to FINRA CAT's proposed operating fees to maintain the functionality, as it is an extension of other required system elements (

e.g.,

linkage).

148

CAT LLC states that the only ongoing cost for any such ad hoc processing of Late Reported Data would be due to incremental cloud hosting fees associated with each ad hoc processing request.

149

147

See id.

at 61519 n.83.

148

See id.

149

See id.

CAT LLC states that the Late Data Re-Processing Amendment would reduce CAT costs for cloud hosting services by approximately $14 to $19 million annually, plus a $300,000 reduction to the Plan Processor annual operating fee.

150

CAT LLC states that the estimated annual cloud hosting cost savings from the exemptive relief granted in the 2025 Cost Savings Exemptive Order relating to late data re-processing is approximately $12.5 to $17, meaning that the incremental savings of the Late Data Re-Processing Amendment as compared to the exemptive relief granted in the 2025 Cost Savings Exemptive Order relating to late data re-processing is approximately $1.5 to $2 million.

151

CAT LLC states that to implement the proposal, the Plan Processor has proposed a one-time change request setting forth an implementation fee of approximately $250,000-$500,000, and that the Plan Processor estimates that it would take approximately two to four months to fully implement the changes for the Late Date Re-Processing Amendment.

152

150

See id.

at 61517.

151

See id.

152

See id.

at 61520. One-time implementation costs will generally consist of Plan Processor labor costs associated with coding and software development, as well as any related cloud fees associated with the development, testing, and load testing of the proposed changes for the proposed amendment.

Id.

Two commenters state that they support the Late Data Re-Processing Amendment.

153

One of these commenters states that it supports the Late Data Re-Processing Amendment, as well as the other amendments, based on the projected cost savings to the CAT system, and further states that these amendments would not impact the quality of CAT data, do not raise security concerns, and would not increase the compliance and operational costs for Industry Members.

154

153

See

FIF February 2026 Letter, at 2, 4; SIFMA March 2026 Letter at 6-7.

154

See

FIF February 2026 Letter, at 4.

In response to Commission staff questions, CAT LLC states that the Late Data Re-Processing Amendment is designed to eliminate all Enhanced Late to the Lifecycle and Full Replay re-processing in order to realize significant cost savings, not to preserve it through ad hoc requests or to codify an ad hoc requirement into the CAT NMS Plan.

155

CAT LLC states that the Proposed Amendment would eliminate any requirement, obligation, or expectation under the CATNMS Plan to conduct such re-processing in any manner, and that while it would remain theoretically possible to conduct such re-processing in extraordinary circumstances,

156

the objective is to eliminate this process entirely.

157

CAT LLC states that introducing an ad hoc requirement would introduce costs that would undermine the intended savings and would be inconsistent with the premise of this proposal.

158

CAT LLC also states that pursuant to the Late Data Re-Processing Amendment, records received after T+4 at 8 a.m. Eastern Time would not receive any standard lifecycle enrichments under the Late Data Re-Processing Amendment, which includes CAT Lifecycle ID, CAT FDID,

159

Lifecycle Sequence, Associated Lifecycles, Link Status Code, Unlinked Flag, CAT Venue Order ID, Multi-lifecycle Flag, and Top Indicator.

160

155

See

CAT LLC March 2026 Response Letter, at 3.

156

See id.

CAT LLC states an example of extraordinary circumstances were if the Commission were to issue an emergency order directing CAT LLC to perform re-processing of late reported data.

Id.

CAT LLC states that absent a Commission order, all decisions regarding whether to perform Enhanced Late to the Lifecycle or Full Replay re-processing on an ad hoc basis will be at the sole discretion of the Operating Committee, taking into account any associated costs.

Id.

at 3 n.9.

157

See id.

at 3.

158

See id.

159

See id.

CAT LLC states that FDID would still be present on Late Reported Data if reported within the record itself; for example, an originating New Equities Order (MENO) or New Options Order (MONO).

Id.

160

See id.

CAT LLC states that the “lifecycle map,” which indicates all lifecycle associations made during the Enhanced Late to Lifecycle process, would continue to exist and reflect lifecycle associations made through prior re-processing of late CAT data, but new entries to the lifecycle map would be recorded only in the limited instances where the Plan Processor has been instructed to perform ad hoc Enhanced Late to Lifecycle or Full Replay re-processing.

Id.

Even though the percentage of CAT Data that is Late Reported Data is small,

161

not re-processing all Late Reported Data received after T+4 at 8 a.m. could have a materially negative

impact on the quality of CAT Data. Therefore, the Commission is modifying the proposed Late Data Re-Processing Amendment to codify exemptive relief removing the need to perform “Full Replay” re-processing, require “Enhanced Late to the Lifecycle” processing on a quarterly basis for trade dates within the prior 3 years, require the Plan Processor to maintain lifecycle mapping that indicates all lifecycle associations made during the “Enhanced Late to the Lifecycle” process, and provide for ad hoc requests for Full Replay re-processing. This approach to late data re-processing is consistent with the approach provided in the 2025 Cost Savings Exemptive Relief Order.

162

In the context of a market data analysis, a small percentage of uncorrected linkages and unlinked CAT Data increases error rates and could distort results or findings if the errors and late data of a relevant data set are substantial or particularly meaningful with respect to the specific market data analysis being performed. The Commission's modification will result in the Plan Processor continuing to run the Enhanced Late to the Lifecycle Process as currently done pursuant to the 2025 Cost Savings Exemptive Relief Order. As such, pursuant to the Late Data Re-Processing Amendment as modified by the Commission, regulatory users will maintain the ability to quickly and reliably identify and link all relevant lifecycles associated with late-reported data, although more manual intervention would be required than if Full Replay re-processing were implemented.

163

The Late Data Re-Processing Amendment as proposed, without the Enhanced Late to the Lifecycle Process, would require regulators to rely on summary statistics and manual review and sequencing,

164

such that identifying and linking relevant lifecycles would be a difficult, time-consuming, and potentially inaccurate process. These concerns must be balanced against the cost savings associated with the Late Data Re-Processing Amendment.

161

See

Notice, at 61520 (stating that in the past year, only 0.82% of Reportable Events were reported late, and only 0.07% of Reportable Events required re-processing).

162

CAT LLC states that all Participants believe that the Late Data Re-Processing Amendment's approach would be sufficient for their regulatory purposes and is vastly preferable to routinely incurring the current, significant costs of regular, automated re-processing.

See id.

The cessation of all late data re-processing could have an impact on the regulatory use of CAT by the Commission, and the Commission does not believe that at this time it would be appropriate to stop all late data re-processing for an estimated incremental cost savings of $1.5 to $2 million.

163

The Full Replay process is functionality designed to present regulatory users post-T+5 data in a manner substantially similar to how such data would have been presented if it had been reported prior to T+5, including by replicating and replaying records with enrichments impacted by post-T+5 submissions, creating updated enrichments, and persisting the replicated records within the underlying data.

See

2025 Cost Savings Exemptive Relief Order, at 47856. By contrast, the Enhanced Late to the Lifecycle Process requires regulatory users to take additional steps to gather information about all related lifecycles together in instances where late-reported data requires such re-processing.

164

See

Notice, at 61519 (stating that the distinction between trade date and submission date will be available on a record-by-record basis in the Central Repository and that regulators can identify and review late data submissions by leveraging summary statistics provided by the Plan Processor, by reviewing the catalog of data issues updated daily in the data issue search system, and by reviewing the underlying records themselves).

For the reasons discussed above, the potential cost savings of the Late Data Re-Processing Amendment do not justify the Participants' proposal to cease re-processing or lifecycle enrichments to Late Reported Data at this time. While the Proposed Amendment states that CAT LLC understands that, with this proposed change, the Plan Processor would retain the ability to perform Late to the Lifecycle and Full Replay reprocessing on an ad hoc basis if required for regulatory purposes,

165

the Proposed Amendment provides no mechanism for performing this reprocessing on an ad hoc basis, other than an “emergency order” from the Commission directing CAT LLC to do so.

166

165

See

Notice, at 61519 n.83.

166

See

CAT LLC March 2026 Response Letter, at 3.

CAT LLC represents that cessation of regular, automated re-processing of Late Reported Data would result in an estimated $14 to $19 million in annual cost savings for cloud hosting services, compared to estimated savings of $12.5 to $17 million from the relief granted by the 2025 Cost Savings Exemptive Order.

167

The incremental savings from the proposed Late Data Re-Processing Amendment compared to the 2025 Cost Savings Exemptive Order is approximately $1.5 to $2 million in estimated annual cloud hosting cost savings, which and for the reasons discussed above, does not at this time justify the elimination of all late data re-processing.

167

See

Notice, at 61517.

Thus, pursuant to Rule 608(b)(2),

168

the Commission deems it appropriate to modify the Late Data Re-Processing Amendment. These changes will result in amending the plan to be consistent with the exemptive relief related to late data re-processing granted in the 2025 Cost Savings Exemptive Order. Specifically, the Commission is modifying the proposed additional language of Section 6.2 of the CAT NMS Plan to remove a reference to the Exchange Act, require the usage of Enhanced Late to the Lifecycle re-processing on Late Reported CAT Data, and to implement the ability for Participant and Commission staff to request Full Replay re-processing on an ad hoc basis, in a manner similar to that which was proposed for requests for interim processing and linkage in the Interim CAT-Order-ID Amendment, described above in Part III.A. Specifically, the Commission is reverting the deletion of a paragraph in Section 6.2 of Appendix D regarding notification of corrections and modifying the proposed new paragraph in Section 6.2 of Appendix D of the CAT NMS Plan, as proposed by CAT LLC in the Late Data Re-Processing Amendment, and adding three additional new paragraphs to Section 6.2 of Appendix D, as follows, with deletions shown through [brackets], and additions shown with

italics:

168

17 CFR 242.608(b)(2).

6.2 Data Availability Requirements

If corrections are received after T+4, Participants' regulatory staff and the SEC must be notified and informed as to how re-processing will be completed. The Operating Committee will be involved with decisions on how to re-process the data; however, this does not relieve the Plan Processor of notifying the Participants' regulatory staff and the SEC.

Notwithstanding any other requirements of the CAT NMS Plan[, or the Exchange Act or the rules and regulations thereunder], records received after T+4 at 8:00 a.m. Eastern Time will [not ]be subject to [any]

the following

re-processing: [and will be added to the audit trail without any lifecycle enrichments.]

The Plan Processor must perform “Enhanced Late to the Lifecycle” processing for late records with trade dates within the prior 3 years. Under the Enhanced Late to the Lifecycle process, all late records (i.e., records received after T+4) include the date of the correction and, if applicable, the record identifier of the record being corrected as part of normal re-processing. In addition, the late record is associated with all relevant lifecycles as part of normal re-processing, such that order event lifecycles may be associated with more than one CAT Order ID. For all late records, the Plan Processor must run the above-described Enhanced Late to the Lifecycle process no less frequently than quarterly.

The Plan Processor must maintain functionality that creates a lifecycle

mapping which indicates all lifecycle associations made during the Enhanced Late to the Lifecycle process.

Upon requests made by authorized regulatory users from the Participants or the Commission, CAT LLC shall direct the Plan Processor to perform Full Replay re-processing to specified CAT Data, such that late records received through Friday of the prior week are available for regulatory users on the following business day at 8 a.m. Eastern Time, absent extraordinary circumstances. Full Replay functionality must present to regulatory users post-T+5 data in a manner substantially similar to how such data would have been represented if it had been reported prior to T+5, including by replicating and replaying records with enrichments impacted by post-T+5 submissions, creating updated enrichments, and persisting the replicated records within the underlying data.

As proposed, Section 6.2 of the CAT NMS Plan stated that, “[n]otwithstanding any other requirements of the CAT NMS Plan,

or the Exchange Act or the rules and regulations thereunder,

records received after T+4 at 8:00 a.m. Eastern Time will not be subject to any reprocessing and will be added to the audit trail without any lifecycle enrichments.” (emphasis added). However, an NMS plan cannot void or otherwise modify the requirements of the Exchange Act. The CAT NMS Plan is a contractual agreement among the Participants created pursuant to the Exchange Act and, absent an exemption or other relief, the NMS Plan and the Participants themselves are subject to applicable Exchange Act requirements. This includes the rules and regulations thereunder, and as such, the CAT NMS Plan should not state that a provision of the Plan overrides the Exchange Act or the rules and regulations thereunder. The Commission is modifying the Late Data Re-Processing Amendment to restore the deleted paragraph regarding notification to Participants' regulatory staff and the SEC, but is modifying the paragraph to update a reference to “corrections received after T+5” to “corrections received after T+4” to more accurately capture what is considered a late record under current CAT reporting timelines.

169

See also

Notice, at 61517 (defining “Late Reported Data” as late or corrected data received after T+4 at 8 a.m. Eastern Time);

id.

at 61517 n.67 (stating that for purposes of the Proposed Amendment, references to data received “after T+5” or to post-T+5 data, submissions, or reports, are to data received “after T+4 at 8 a.m. Eastern Time”).

The Commission's other modifications to Section 6.2 of Appendix D of the CAT NMS Plan are largely designed to codify the conditional exemptive relief granted in the 2025 Cost Savings Exemptive Order relating to the processing of late CAT data, but modifying the conditions to recognize that “late records” are those that arrive after T+4 at 8 a.m. ET. By codifying the conditional exemptive relief, the core lifecycle linkage functionality envisioned by Rule 613 and the CAT NMS Plan will be preserved.

170

As discussed above, it is not appropriate at this time to fully cease the re-processing of all late data submitted to the CAT. For the less than 1% of late-reported data that does require additional re-processing to construct an order event lifecycle,

171

requiring the Participants to run the Enhanced Late to the Lifecycle process quarterly for trade dates within the prior 3 years and maintain lifecycle mapping should still provide regulatory users with the ability to quickly and reliably identify and link all relevant lifecycles associated with the late-reported data that is most frequently needed and accessed by regulatory users. Although this approach requires some manual intervention by regulatory users, this is a reasonable trade-off for the estimated $12.5 to $17 million dollars of cost savings in estimated annual cloud hosting fees that CAT LLC and the Commission expects will likely flow from limited usage of the Full Replay process and any additional costs savings that may be realized from requiring the Plan Processor to perform the Enhanced Late to the Lifecycle process quarterly instead of weekly.

172

170

See, e.g.,

Securities Exchange Act Release No. 77724 (Apr. 27, 2016), 81 FR 30614, 30693 (May 17, 2016) (“Currently regulators can spend days and up to months processing data they receive into a useful format. Part of this delay is due to the need to combine data across sources that could have non-uniform formats and to link data about the same event both within and across data sources. . . . [T]he Commission preliminarily believes that the Plan would reduce or eliminate the delays associated with merging and linking order events within the same lifecycle.” (footnote omitted));

See also

id.

(stating that the requirement to report rejected order messages applies to Participants, not Industry Members, and, therefore, does not directly affect the reporting and other requirements applicable to Industry Members).

232

See id.

at 61523-24.

However, pursuant to Rule 608(b)(2),

233

the Commission deems it appropriate to modify the amendment to proposed Section 6.3(h) of the CAT NMS Plan as approved to remove a reference to the Exchange Act. As proposed, Section 6.3(h) would state that, “[n]otwithstanding any provision of the CAT NMS Plan (including Appendix D)

or the Exchange Act,

no Participant shall be required to record and electronically report to the Central Repository any order rejected by the Participant nor any Reportable Events related to such rejected order.” (emphasis added). However, an NMS plan cannot void or otherwise modify the requirements of the Exchange Act. The CAT NMS plan is a contractual agreement among the Participants created pursuant to the Exchange Act and, absent an exemption or other relief, the NMS Plan and the Participants themselves are subject to applicable Exchange Act requirements. For these reasons, the Commission deems it appropriate to modify proposed Section 6.3(h) to remove the words, “or the Exchange Act,” to remove the implication that Section 6.3(h) overrides “any provision” of the Exchange Act. In comparison to proposed Section 6.3(h) of the CAT NMS Plan, the following changes apply, with deletions shown through [brackets]:

233

17 CFR 242.608(b)(2).

(h) Rejected Messages. Notwithstanding any provision of the CAT NMS Plan (including Appendix D) [or the Exchange Act], no Participant shall be required to record and electronically report to the Central Repository any order rejected by the Participant nor any Reportable Events related to such rejected order. For the avoidance of doubt, an order that is received by the Participant but not accepted by the Participant is an order rejected by the Participant for purposes of this paragraph.

In addition, although not requested by the Participants, the Commission finds that it is appropriate in the public interest and consistent with the protection of investors under Section 36 of the Exchange Act,

234

235

to grant relief that exempts each Participant from the recordkeeping and data retention requirements for CAT Data subject to the Rejected Message Amendment and that otherwise would apply as set forth in Rule 17a-1 under the Exchange Act. This relief applies only to the Participants' obligation to keep and preserve specific CAT Data within the CAT, and does not apply to any information or records that the Participants are required to keep and preserve outside of the CAT. This exemptive relief would ensure that the Rejected Message Amendment is consistent with Exchange Act requirements.

234

17 CFR 242.608(e).

235

17 CFR 240.17a-1.

F. Data Availability Amendment

The Data Availability Amendment proposes to: (1) extend the time by which raw unprocessed data must be made available to Participants' regulatory staff and SEC from 12 p.m. Eastern Time on T+1 to 8 a.m. Eastern Time on T+2, and (2) extend the time by which final data must be ready for regulators from 8 a.m. Eastern Time on T+5 to 8 a.m. Eastern Time on T+6.

236

See

Notice, at 61524-26.

Sections 6.1, 6.2, and 6.3 of Appendix D of the CAT NMS Plan set forth timelines regarding data availability for regulators. Section 6.1 of Appendix D of the CAT NMS Plan states that the Participants require the following timeframes for the identification, communication, and correction of errors from the time an order event is received by the processor: (1) “Noon Eastern Time T+1 (transaction date + one day)—Initial data validation, lifecycle linkages and communication of errors to CAT Reporters;” (2) “8:00 a.m. Eastern Time T+3 (transaction date + three days)—Resubmission of corrected data;” and (3) “8:00 a.m. Eastern Time T+5 (transaction date + five days)—Corrected data available to Participant regulatory staff and the SEC.” Section 6.2 of Appendix D of the CAT NMS Plan states that “[p]rior to 12:00 p.m. Eastern Time on T+1, raw unprocessed data that has been ingested by the Plan Processor must be available to Participants' regulatory staff and the SEC,” and that “[b]etween 12:00 p.m. Eastern Time on T+1 and T+5, access to all iterations of processed data must be available to Participants' regulatory staff and the SEC.”

237

Section 6.3 of Appendix D of the CAT NMS Plan states that “Raw Unprocessed Data” means “data that has been ingested by the Plan Processor and made available to regulators prior to 12:00 p.m. Eastern Time on T+1,” and states that “Interim Operational Data” means “all processed, validated and unlinked data made available to regulators by T+1 at 12:00 p.m. ET and all iterations of processed data made available to regulators between T+1 and T+5, but excludes the final version of corrected data that is made available at T+5 at 8:00 a.m. ET.”

237

In addition, Section 3.4 of the CAT NMS Plan states that Options Market Maker quotes in Listed Options will undergo ingestion validation only and such unlinked data will be made available to regulators by T+1 at 12 p.m. Eastern Time.

Pursuant to the Data Availability Amendment, Sections 6.1, 6.2 and 6.3 of Appendix D of the CAT NMS Plan would be revised to implement a proposed revised data availability timeline.

238

Section 6.1 of Appendix D of the CAT NMS Plan would be amended to replace references to 8:00 a.m. Eastern Time T+5 with 8:00 a.m. Eastern Time T+6, and make corresponding changes to the times in

Figure A

239

in Section 6.1 of Appendix D of the CAT NMS Plan.

240

Proposed Section 6.2 of Appendix D of the CAT NMS Plan would replace references to 12:00 p.m. Eastern Time on T+1 with references to 8:00 a.m. Eastern Time on T+2 and replace references to T+5 to T+6, as well as specify that processing is a six-day process instead of a five-day process.

241

Proposed Section 6.3 of Appendix D of the CAT NMS Plan would replace a reference to 12:00 p.m. Eastern Time on T+1 to 8:00 a.m. Eastern Time on T+2 with respect to Raw Unprocessed Data older than 15 days.

242

238

See

Notice, at 61524-25.

239

Figure A is a chart within Section 6.1 of Appendix D of the CAT NMS Plan that is labeled CAT Central Repository Data Processing Timelines.

240

See id.

at 61525.

241

See id.

242

See id.

CAT LLC states that the Data Availability Amendment would reduce CAT costs for cloud hosting services by approximately $1.5 to $2 million annually.

243

CAT LLC states that assuming CAT Data is required to be made available on a daily basis, expanding the data availability timeline beyond T+2 and/or T+6 would not result in additional material cost savings because the Plan Processor would still be required to process the same amount of data.

244

CAT LLC states that to implement the proposal, the Plan Processor has proposed a one-time change request setting forth an implementation fee of approximately $200,000—$400,000, and that the Plan Processor estimates that it would take approximately three to six months to fully implement the changes for the Data Availability Amendment.

245

243

See id.

244

See id.

at 61525 n.112.

245

See id.

at 61525. One-time implementation costs will generally consist of Plan Processor labor costs associated with coding and software development, as well as any related cloud fees associated with the development, testing, and load testing of the proposed changes for the proposed amendment.

Id.

Two commenters state that they support the Data Availability Amendment.

246

One of these commenters states that it supports the Data Availability Amendment, as well as the other amendments, based on the projected cost savings to the CAT system, and further states that these amendments would not impact the quality of CAT data, do not raise security concerns, and would not increase the compliance and operational costs for Industry Members.

247

246

See

FIF February 2026 Letter, at 2, 4; SIFMA March 2026 Letter, at 6-7 (noting that this was addressed in the 2025 Cost Savings Exemptive Order).

247

See

FIF February 2026 Letter, at 4.

The Data Availability Amendment would provide for substantial cost savings with limited regulatory impact and without having an adverse impact on Industry Members. The Data Availability Amendment would provide the Plan Processor with additional time to process the extremely large data volumes handled by the CAT on an ongoing basis, while only delaying the availability of processed and linked CAT Data to regulators by one day.

248

Importantly, CAT LLC states that changing the timelines for providing data to the regulators would not directly affect the reporting and other requirements applicable to Industry Members.

249

248

It is reasonable to only delay the availability of data by one day because CAT LLC states that assuming CAT Data is required to be made available on a daily basis, expanding the data availability timeline beyond T+2 and/or T+6 would not result in additional material cost savings because the Plan Processor would still be required to process the same amount of data.

See

Notice, at 61525 n.112.

249

See id.

at 61525.

CAT LLC states that the Participants “unanimously agree” that obtaining a final lifecycle by T+6, in lieu of T+5, is sufficient to conduct their regulatory programs.

250

The Commission agrees that a delay of one day for the receipt of final lifecycles is sufficient to conduct regulatory programs, and that it would not unduly impact regulatory use of CAT Data. In addition, should the Participants or the Commission want processed and linked data sooner, as discussed in Part III.A. above, the Interim CAT-Order-ID Amendment provides a mechanism for Participant and Commission staff to request such interim processing be done. The cost savings are a reasonable trade-off for the elimination of the regulatory benefit of maintaining the T+5 timing, because even if there were a major market event or a regulatory need for linked data where receiving linked data at T+5 instead of T+6 could be relevant or important, the Participants and Commission would have access to interim linked data pursuant to the ad hoc request ability.

250

See id.

It is reasonable to have access to raw unprocessed data ingested by the Plan Processor prior to T+2 at 8 a.m. Eastern Time. Having access to raw unprocessed data a day earlier, at T+1 at 8 a.m. Eastern Time, is generally not critical for regulatory users. Linked data is of greater regulatory value, and as noted above, the Interim CAT-Order-ID Amendment would provide a mechanism for requesting that the raw unprocessed data be quickly processed and linked for regulatory use.

The Commission is modifying the Proposed Amendment, pursuant to Rule 608(b)(2),

251

to modify existing CAT NMS Plan language to fix a technical issue and make the provision consistent with the Data Availability Amendment, and consistent with a proposed modification in the CAT LLC February 2026 Letter.

252

Specifically, Section 3.4 of the CAT NMS Plan currently states that OMM Quotes will undergo ingestion validation only and such unlinked data will be made available to regulators by T+1 at 12:00 p.m. Eastern Time. To be consistent with the Data Availability Amendment and the timing of the provision of other unprocessed CAT Data to regulatory users, the Commission is modifying Section 3.4 of the CAT NMS Plan to replace “T+1 at 12:00 p.m. Eastern Time” with “T+2 at 8:00 a.m. Eastern Time.” This modification is appropriate, because it makes this provision consistent with the Data Availability Amendment and would help avoid confusion about when data would be made available to regulators pursuant to the Proposed Amendment.

251

See

CAT LLC February 2026 Letter, at 3.

252

17 CFR 242.608(b)(2).

G. Reference Data Amendment

The Commission recently approved an amendment to the CAT NMS Plan that eliminated all CAT NMS Plan requirements to report Names, Addresses, YOBs, SSNs/ITINs, and EINs to the CAT and to remove such previously reported customer information stored in the CAT,

253

as well as codified the Participants' current method of generating anonymized customer identifiers (“CAT Customer-IDs” or “CCIDs”) without requiring the receipt or storage of individual SSNs/ITINs in the CAT.

254

253

See

CAIS Amendment Approval Order. This effectively codified and expanded upon prior exemptive relief from the requirement to report Names, Addresses, and YOBs for natural persons with social security numbers or tax-payer identification numbers.

See

Securities Exchange Act Release No. 102386 (Feb. 10, 2025), 90 FR 9642, 9643 (Feb. 14, 2025),

https://www.sec.gov/files/rules/sro/nms/2025/34-102386.pdf

(“CAIS Exemption Order”).

254

See

CAIS Amendment Approval Order, at 2166. Pursuant to the CCID alternative, the Plan Processor generates a unique CCID, using a two-phase transformation process that avoids having individual social security numbers or tax-payer identification numbers (“SSNs/ITINs”) reported to or stored in the CAT. In the first transformation phase, a CAT Reporter transforms the SSN/ITIN into an interim transformed value. This transformed value, and not the SSN/ITIN, is submitted to a separate system within the CAT (“CCID Subsystem”). The transformed value is sent to the CAT separate and apart from the other customer and account information. The CCID Subsystem then performs a second transformation to create the

globally unique CCID for each Customer that is unknown to, and not shared with, the original CAT Reporter. The CCID is then sent to the customer and account information system (“CAIS”) of the CAT, where it is linked with the other customer and account information. The CCID may then be used by the Participants' regulatory staff and Commission staff in queries and analysis of CAT data.

See

Securities Exchange Act Release No. 88393 (Mar. 17, 2020), 85 FR 16152, 16153 (Mar. 20, 2020),

https://www.govinfo.gov/content/pkg/FR-2020-03-20/pdf/2020-05935.pdf

(“CCID Exemption Order”).

The Initial Proposed Amendment included proposed amendments to the CAT NMS Plan to eliminate both the requirement to report Customer Account Information and Customer Identifying Information to the CAT, eliminate CAIS from the CAT, and adopt a new approach for the generations of CCIDs (“Reference Data Amendment”). The CAIS Amendment was approved after the submission of the Initial Proposed Amendment, and thus the proposed Reference Data Amendment in the Initial Proposed Amendment included changes to the CAT NMS Plan based on the text of the CAT NMS Plan prior to the approval of the CAIS Amendment.

255

On February 24, 2026, CAT LLC submitted CAT LLC February 2026 Letter, which proposed revisions to the Initial Proposed Amendment to reflect the intervening changes to the language of the CAT NMS Plan following the Commission's approval of the CAIS Amendment.

256

On March 10, 2026, CAT LLC submitted CAT LLC March 2026 Response Letter, which proposes one additional revision to the Proposed Amendment, further revising the proposed definition of “Reference Data” to include “Customer Type.”

257

255

See

Notice, at 61509 n.15 (stating that the SEC has not yet approved or disapproved the CAIS Amendment).

256

See

CAT LLC February 2026 Letter,

supra

note 7.

257

See

CAT LLC March 2026 Response Letter, at 9.

The Reference Data Amendment, as proposed to be changed by the CAT LLC in its February 2026 Response Letter, differs from the CAIS Amendment in that it proposes to, as described in greater detail below: (i) eliminate the requirement to report Account Reference Data and Customer Reference Data to the CAT; (2) eliminate CAIS from the CAT and instead establish the Reference Database;

258

and (3) utilize a revised approach for the generation of CCIDs that minimizes the data needed for its creation (the “Reference Data Approach”).

259

Under the Reference Data Approach, certain previously required information would not be reported to the CAT, such as Large Trader IDs (“LTIDs”) and Legal Entity Identifiers (“LEIs”), and the Reference Database would be limited to the storage of CCID Generation Data and CCID Transaction Enrichment Data, as defined below, as well as account type, clearing broker, branch office, registered representative, and individual's role in the account.

258

The Reference Database would not include the same information as the CAIS, and regulatory and other features related to the CAIS and the collection of Customer information (

e.g.,

Regulatory Portal, CAIS Report Card, CCID Rotation) would also be eliminated.

See

Notice, at 61528.

259

CAT LLC further states that the CAIS Amendment involves targeted changes to the broader CAIS infrastructure, while fully eliminating CAIS and related functionality would be simpler and more straightforward, and therefore less time consuming.

See

CAT LLC March 2026 Response Letter, at 6-7. CAT LLC states that, if approved, the Reference Data Amendment would effectively supersede the CAIS Amendment, and the associated implementation costs would be lower than those under the CAIS Amendment.

Id.

at 7.

CAT LLC states that pursuant to the Reference Data Approach, Industry Members would be required to collect and record certain identification information for their Customers (such as SSNs, ITINs, Employer Identification Numbers (“EINs”) or foreign identifiers, collectively “CCID Generation Data”), and instead of submitting such information to the CAT, each Industry Member would submit to the Reference Database of the CAT (the information system of the CAT that would contain Reference Data) (1) the hashed version of each Customer's identification information, which would be referred to as the Transformed Identifier or TID, as well as (2) the type of identifier used to create the Transformed Identifier (

e.g.,

SSN/ITIN, EIN or foreign identifier), and such type of identifier would be referred to as the Transformed Identifier Type or TID Type.

260

CAT LLC states that the process for generating CCIDs from this information would be materially the same as the current process, using a combination of TID, TID Type, Foreign TID Type and Foreign TID Country Codes to generate CCIDs based on a combination of these field values.

261

260

See

Notice, at 61528. For foreign Customers, each Industry Member would be required to submit two items in addition to the TID and TID Type; Industry Members also would be required to submit (1) the Foreign TID Type, which is the type of foreign identifier used to create the TID (

e.g.,

passport, LEI, driver's license), and (2) the Foreign TID Country Code, which is the country that issued the foreign identifier used to create the TID.

Id.

261

See id.

CAT LLC states that Industry Members would be required to submit to the Reference Database that replaces the CAIS database, certain “CCID Transaction Enrichment Data” for each account and Customer, as applicable: (i) Firm Designated ID; (ii) Date FDID Opened, which means the date the account was opened (or the Account Effective Date); (iii) Date FDID Closed, which means the date the account was closed (or relationship or entity identifier was ended) at the Industry Member; (iv) Customer Role Start Date, which means the date the Customer became associated with the account; and (v) Customer Role End Date, which means the date the Customer is no longer associated with the account.

262

Furthermore, CAT LLC states that Industry Members would be required to report to the Reference Database the following data types: account type, clearing broker, branch office, registered representative, and individual's role in the account.

263

262

See id.

263

See id.

Pursuant to the Reference Data Approach, Reference Data, which includes CCID Generation Data, CCID Transaction Enrichment Data, and account type, clearing broker, branch office, registered representative, and individual's role in the account, would be reported to and collected in the Reference Database.

264

In addition, CAT LLC states that the Plan Processor would enrich Reportable Events for an order with the CCID for the relevant Customer using the FDID as the key and map CCIDs to FDIDs, which would allow regulators to associate a Customer with transaction data.

265

CAT LLC states that once the Plan Processor enriches Reportable Events with the CCID, regulators can track the same CCID and Customer across different FDIDs and across different Industry Members.

266

CAT LLC states that with the elimination of CAIS, the CAIS regulatory portal would be eliminated, but that to the extent that a regulator needs to use a social security number, EIN, or foreign identifier (which it has obtained from outside the CAT) to investigate CAT activity, the Plan Processor would provide a method (

e.g.,

an application programming interface (“API”)) that would permit regulators to use the social security number to look up a CCID.

267

264

See id.

CAT LLC states that with the elimination of the CAIS database, regulatory and other features related to CAIS and the collection of Customer information (

e.g.,

Regulatory Portal, CAIS Report Card, CCID Rotation) also would be eliminated.

See id.

265

See id.

CAT LLC states that under the Reference Data Approach, the mapping table would be expanded to include the additional Reference Data elements, and relevant historical CCID, FDID and Reference Data will be migrated to the updated mapping table; with such migration, such relevant historical data would not be eliminated.

See id.

266

See id.

267

See id.

at 61528-29.

CAT LLC states that the Reference Data Amendment, as proposed in the

Initial Proposed Amendment, would reduce CAT costs for cloud hosting services by approximate $4 to $6 million annually, as well as provide for potential reductions in the operating fees for the Plan Processor.

268

In the Initial Proposed Amendment, CAT LLC states that the potential cost savings related to the operating fees for the Plan Processor with regard to the 2025 Cost Savings Amendment are $7 million.

269

CAT LLC states that while the November 2025 CAT budget includes approximately $24.5 million in CAIS-related Plan Processor fees, including a $20.7 million in CAIS operating fee and a $3.8 million license fee,

270

which would be eliminated with the elimination of CAIS, the elimination of these fees would be offset in part by other estimated increases in Plan Processor fees, resulting in total Plan Processor fees of approximately $47 million on an annualized basis, an estimate $7 million reduction from the $54 million in total Plan Processor fees under the proposed 2025 Cost Savings Amendment.

271

CAT LLC states that to implement the Reference Data Amendment, as proposed in the Initial Proposed Amendment, the Plan Processor has proposed a one-time change request implementation fee of approximately $2.5-$3.5 million, and that the Plan Processor estimates that it would take approximately nine to twelve months, including an allowance for three to four months for industry testing, to fully implement the changes for the Reference Data Amendment.

272

268

See

Notice, at 61526.

269

See id.

270

See id.

at 61526 n.114.

271

See id.

at 61526.

272

See id.

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